What travel policies have restricted or allowed the movement of foreign nationals across the WHO European region?

Cross-Country Analysis

What travel policies have restricted or allowed the movement of foreign nationals across the WHO European region?

Since the beginning of the COVID-19 pandemic, countries across the WHO European Region have imposed restrictions on international travel.

These have included entry bans, testing and quarantine measures which fluctuate weekly or biweekly based on a set of criteria such as the status of the epidemiological situations in countries of departure and arrival and the emergence of variants of concern. This policy analysis investigates how specific travel policies implemented by Member States across the WHO European Region have affected the free movement of foreign nationals, offering an expanded analysis up to May 2021. Changes in travel policies over the course of the pandemic are also highlighted, in response to advances in vaccine availability and use. The analysis does not assess the impact of travel policies on the epidemiological situation in Member States. A previous HSRM policy snapshot looked at how countries were adjusting international travel in the context of COVID-19, and what criteria they used to inform decision making.

Information was collected from open sources including government, intergovernmental and supranational organizations’ webpages by the COVID-19 Incident Management Support Team of the WHO Regional Office for Europe and the COVID-19 Health Systems Response Monitor (HSRM). Selected examples are provided from the following countries: Armenia, Belarus, Belgium, The Czech Republic, Croatia, Cyprus, Estonia, Finland, Germany, Iceland, Ireland, Italy, Latvia, Lithuania, the Netherlands, Norway, Portugal, Slovakia, Spain and the Russian Federation. In addition, examples include recommendations and approaches to implementation of international travel restrictions by WHO, the European Commission (EC), the Council of the European Union (EU) and the Eurasian Economic Union (EAEU). This analysis aims to inform Member States on different approaches to implementation of international travel restrictions that have affected the movement of foreign nationals during the COVID-19 pandemic.

Foreign nationals have been affected by entry bans via air, land, sea and visa restrictions

Since the beginning of the pandemic in January 2020, all 53 Member States of the WHO European Region have implemented international travel measures comprising entry bans for people arriving via air, land and sea, quarantine measures for travellers who were allowed entry, or a variety of COVID-19 testing requirements before departure, on arrival or after entry (follow-up tests). Countries usually prioritize facilitating entry of their national citizens, sometimes subject to testing or quarantine requirements. However, the majority of strict international travel measures, such as entry bans have affected foreign nationals, based on their nationality or country of departure.

By 20 May 2021, the majority of countries had implemented travel bans for international arrivals via air (49 countries), land (46 countries) or sea (39 countries) for targeted categories of foreign nationals. Some 18 countries also implemented entry bans via visa restrictions. Travellers who were still allowed entry were often subject to testing and quarantine requirements. Figure 1 below provides a broad overview of the level of severity of international travel restrictions implemented by countries of the WHO European Region from the beginning of the pandemic until 20 May 2021, comprising entry bans, visa restrictions, and testing and quarantine requirements.

Figure 1. Historical progression of the severity of travel restrictions across the WHO European region (as of 20 May 2021) 

Specific groups of foreign nationals have been allowed entry as exemptions to entry bans

Where broad entry bans have been implemented with exceptions, countries have implemented flexible regulations throughout the pandemic to allow entry for specific foreign nationals. For example, the Netherlands allowed business travellers, students, highly skilled migrants, professionals from the cultural and creative sector and partners of EU citizens who were from outside the EU to enter as exceptions to their general entry ban. Iceland allowed foreign nationals who were exempt from visa requirements and who work for Icelandic companies to stay in Iceland for up to 6 months, instead of the previous 90 days. Estonia introduced a new type of visa called the “new Digital Nomad Visa” allowing remote workers to live in Estonia and legally work for their employer or their own company registered abroad. Furthermore, the Czech Republic allowed entry for cross border workers, students, professional athletes and diplomats without the need to present a COVID-19 test or quarantine upon arrival. The Russian Federation also allowed entry for foreign athletes, coaches and physical fitness specialists to enter under work or humanitarian visas.

Since the beginning of the pandemic, Norway had some of the strictest entry restrictions in place, but continued to allow entry for foreign nationals whose skills are essential to the economy.  

Regional blocs have allowed movement of foreign nationals based on bilateral and multilateral agreements

Within the EU, as a result of the uncoordinated approach to the implementation of travel restrictions, on 13 October 2020, the Council of the EU adopted a recommendation on a coordinated approach to the restrictions on free movement in response to the COVID-19 pandemic, based on common criteria and the weekly mapping of countries by European Centre for Disease Prevention and Control (ECDC) into red, orange, green and grey zones. This mechanism facilitates Member States to allow the free movement of all EU citizens and legal residents, only applying testing and/or quarantine measures to travellers from non-green areas. On 25 January 2021, this recommendation was updated to include an additional ‘dark red’ zone due to the worsening epidemiological situation in many countries, and offered advice for countries to implement stricter measures for arrivals from high-risk areas, such as pre-departure or post-arrival testing and quarantine.

As of 28 April 2021, according to the official EU re-open webpage, three countries (Croatia, Ireland, Spain) have fully adapted the EU traffic light approach, while 28 EU/Schengen countries have either adopted their own national risk assessment or adapted the ECDC approach. For example, Croatia has implemented the EU traffic light approach, with additional requirements to register online before arrival, while Italy has classified countries from List A to List E, and requires a self-declaration form, and quarantine or testing based on the different lists.

The Eurasian Economic Union is an international organization for the regional economic integration of five Member States: Armenia, Belarus, Kazakhstan, Kyrgyzstan and the Russian Federation. Recently, Armenia, Belarus and Russia joined a pilot project, the “Traveling without COVID-19” app, which allows for the free movement of passengers between the three countries by uploading a negative PCR test result to the mobile app and presenting the results to officials at borders through a QR code.

Similarly, in May 2020, Baltic states such as Lithuania, Estonia and Latvia created a travel bubble between the three countries by lifting the requirement to quarantine upon arrival for their citizens. However, by April 2021, Latvia, Lithuania and Estonia reimposed quarantine measures for 10 days, as a result of the worsening epidemiological situation.

The European Union adapted a specific travel policy for entry of non-EU travellers into the EU/Schengen area

On 30 June 2020, the Council of the European Union adopted a recommendation on the gradual lifting of temporary restrictions on non-essential travel into the EU. EU Member States were encouraged to start lifting travel restrictions from 1 July 2020 at external borders for residents of the following 15 third countries: Algeria, Australia, Canada, Georgia, Japan, Montenegro, Morocco, New Zealand, Rwanda, Serbia, South Korea, Thailand, Tunisia, Uruguay and China (subject to confirmation of reciprocity). Countries on the list were chosen based on:

  • containment measures and epidemiological criteria such as number of new COVID-19 cases over the last 14 days and per 100 000 inhabitants close to or below the EU average;
  • stable or decreasing trend of new cases over this period in comparison to the previous 14 days;
  • overall response to COVID-19 taking into account available information, including on aspects such as testing, surveillance, contact tracing, containment, treatment and reporting; and
  • the reliability of the information and, if needed, the total average score for International Health Regulations (IHR).

By 28 January 2021, this EU recommendation had been updated six times (on 16/07/2020, 30/07/2020, 07/08/2020, 22/10/2020, 17/12/2020, 28/01/2021) based on the same criteria, but containing a dwindling list of countries, including Australia, New Zealand, Rwanda, Singapore, South Korea, Thailand and China (subject to confirmation of reciprocity). Croatia, Portugal and Spain have fully adopted EU recommendations regarding the list of countries, whereas Germany and Slovakia excluded Rwanda from their lists, and several EU countries left out China. While the recommendation proposed entry without restrictions, Portugal required travellers from this list to present a negative RT-PCR test carried out 72 hours before boarding, while Croatia allowed entry without additional testing or quarantine requirements.

By 2 February 2021, the updated recommendation included new epidemiological criteria, including the detection of variants of concern. Additionally, Member States were encouraged to reintroduce travel measures such as pre-departure PCR tests valid for 72 hours, or quarantine of up to 14 days, in instances where the epidemiological situation worsens quickly and, in particular, where a high incidence of variants of concern were detected.

Essential travel is the main purpose for entry of foreign nationals following the detection of new variants of concern

During the COVID-19 pandemic, WHO has recommended that international travel should always be prioritized for emergencies and humanitarian actions, travel of essential personnel, repatriations, and cargo transport for essential supplies such as food, medicines, and fuel. On 19 January 2021, the European Commission in a circular to Member States discouraged all non-essential travel, especially to and from high-risk areas, until the epidemiological situation improved, particularly in the light of outbreaks of variants of concern. Subsequently countries like Finland, Latvia, Belgium and the Czech Republic restricted entry for foreign nationals, even from other EU countries, except for essential reasons defined by the government such as work, studies, receiving medical services and family reunification, among others. These travellers are still subject to additional requirements such as testing or quarantine measures.

As of 20 May 2021, 36 countries have implemented stricter travel-related measures in the context of SARS-COV-2 variants of concern, including entry bans, testing requirement and/or quarantine restrictions for international travellers from different countries, including the United Kingdom, South Africa, Brazil and India.

Proof of vaccination is being used as an option to allow entry along with testing or quarantine measures

Since the beginning of the pandemic, there have been discussions on the role vaccination could play in the easing of public health and social measures, including international travel measures. By 3 May 2021, the availability and use of vaccines in a growing number of Member States has seen vaccination certificates introduced as an additional option to testing and/or quarantine measures in 15 Member States, while 8 Member States have indicated the future use of vaccination certificates to resume international travel.

In the EU, the EU Commission on 17 March 2021 introduced a proposal for a legislative framework for the implementation of a Digital Green Certificate, which covers three different types of COVID-19 certificates: a vaccination certificate, a test certificate, and a certificate of recovery. This initiative will waive restrictions to free movement put in place in a Member State on public health grounds, such as testing or quarantine requirements. It is WHO’s position at the time of writing that national authorities and conveyance operators should not introduce requirements of proof of COVID-19 vaccination for international travel as a condition for departure or entry, given that there are still critical unknowns regarding the efficacy of vaccination in reducing transmission, in addition to particular scientific, ethical, legal and technical considerations.

EU countries intend to use vaccination certificates for international travel by summer 2021

On 29 April 2021, the European Parliament adopted its negotiating position on the proposal for a certificate to reaffirm the right to free movement in Europe during the pandemic. It was proposed that the certificate should be called the “EU digital COVID-19 certificate” instead of the Digital Green Certificate and should be in place for 12 months and not longer. The document, which may be in digital or paper format, will attest that a person has been vaccinated against coronavirus or, alternatively, that they have a recent negative test result or have recovered from the infection. However, EU COVID-19 certificates will neither serve as a travel document nor become a precondition to exercise the right to free movement. By 20 May 2021, the Council of the EU and the European Parliament reached a provisional political agreement. The name “ EU digital COVID-19 certificate” was adopted, and it was agreed that COVID-19 tests would be made affordable and accessible. Furthermore, Member States would only introduce additional measures such as quarantine if necessary to safeguard public health, and in a timely manner. It is expected that after voting and adopting this agreement, the EU COVID-19 certificate will be operational from 1 July 2021.

On 3 May 2021, the European Commission proposed that Member States allow entry into the EU for non-essential reasons not only for all persons coming from countries with a good epidemiological situation but also for all people who have received the last recommended dose of a vaccine authorised by the European Medicines Agency (EMA). Member States could also extend this to those vaccinated with a vaccine having completed the WHO emergency use listing process. Where Member States accept proof of vaccination in order to waive other restrictions, such as quarantine/self-isolation or testing, they should also waive these requirements for travellers resident in a third country provided that they have received the last recommended dose of a COVID-19 vaccine (authorised by the EMA or the WHO Emergency Use Listing process) at least 14 days before entering the EU/EEA. Until the EU digital COVID-19 certificate is operational, Member States are encouraged to accept vaccination certificates from non-EU countries based on national law.

Conclusion: International travel policies should be coordinated at national and international levels based on the latest available scientific evidence

Since March 2020, all Member States in the WHO European Region have restricted and/or put in place conditions for entry such as requiring quarantine and/or testing for foreign nationals upon entry to try to reduce the spread of COVID-19, including new variants of concern. The measures implemented have significantly reduced the free movement of foreign nationals to countries in the WHO European Region, and unions of countries formed within. However, to keep economies and societies going, many countries implemented specific travel policies which have exempted certain categories of foreign travellers such as business travellers, workers of certain professions with essential skills, and students from their entry restrictions. In addition, many countries exempt or impose less strict entry restrictions to cross-border workers living in immediate border areas or performing seasonal agricultural work to reduce the negative economic impact caused by restricted entry.

Even though unified approaches and strategies have been observed within the WHO European Region, such as ‘travel bubbles’ and traffic light systems guiding quarantine and testing requirements, several countries have implemented their own approaches and strategies. As COVID-19 vaccines are being rolled out and the percentages of vaccinated people in countries are increasing, many countries are considering introducing a system allowing foreign nationals to enter without restriction by showing a COVID-19 certificate at the border, such as proof of vaccination, proof of recovery from COVID-19, or a negative COVID-19 test result.

In light of SARS-COV-2 variants of concern and vaccination rollout in countries, national authorities should continue to conduct a regular, systematic risk assessments and to inform all travellers of the introduction, adjustment and discontinuation of risk mitigation measures in the context of international travel. This risk assessment approach should take into consideration the local epidemiology, travel volumes, public health and health services capacity, Public Health and Social Measures implemented in the country as well as additional contextual factors including economic impact, human rights, and evidence on adherence. It is WHO’s position that countries should prioritize vaccination for seafarers and air crews in line with the Joint statement on their prioritization. However, countries should not require proof of vaccination as a condition of entry given the limited (although growing) evidence about the performance of vaccines in reducing transmission and the persistent inequity in the global vaccine distribution. Countries are strongly encouraged to acknowledge the potential for requirements of proof of vaccination to deepen inequities and promote differential freedom of movement.

Jennifer Addo, Sandra Lindmark, Tanja Schmidt, Ute Enderlein, Ihor Perehinets