Passport and associated rights discussion

[Cloud Strife]

Moderator note - split from:

Introduction of EES

I am intending to travel to Vienna at the end of October, then subsequently travel to Germany, and then return to the UK in early November. I understand that it is intended to introduce the EES at the beginning of November (the new cubicles seem to be all powered up and running when I passed...

www.railforums.co.uk

Legally you would need an ETIAS to proceed to Denmark.

Yes, it's highly likely that they'll be checking this in the Faroes and Greenland for non-Nordic passengers to ensure that they're permitted to enter Denmark.

However, Faroese people are treated as EU citizens in the EU without needing to have a connection with Denmark first.

It's actually a bit more complicated than that. If you're Faroese or living in the Faroe Islands as a normal (mainland Europe) Danish citizen, you can pick between having a green Danish-Faroese passport, or a regular red Danish passport. The Danish passport is needed if you want to benefit from the EU's freedom of movement regulations, while the Danish-Faroese passport only allows you to live in Danish territories. It's the same with Greenland. They can't vote in EU elections as well.

It's worth pointing out that EU citizens can't just go and work in the Faroe Islands, they need a work permit. There are some other strange rules too, such as EU ID cards issued to non-Nordic citizens are not valid for obtaining a residence permit in the Faroe Islands, you need a passport.

In practice, the Faroese/Greenlandic passports are treated as normal Danish passports in the EU and so they have full FoM rights, probably because it would be too much hassle to actually differentiate between 'those with Faroese/Greenlandic passports who moved from the EU' and 'those who didn't move from the EU and therefore don't have the right to FoM'. Strictly speaking, holders of those passports should be asked to prove that they've been resident in Denmark first, but this is rarely/never asked for in practice, not least because the information page on the passport confirms them to be Danish citizens, only with two nationalities - Danish and Faroese.

If I understand the Gibraltar-Schengen agreement correctly, it seems that Gibraltar will not be part of Schengen in name only. British citizens resident in Gibraltar would theoretically only be able to spend 90 out of 180 days in Schengen and then would need to return to Gibraltar? This would be difficult to enforce in practice.

What's happening there is still completely unclear, but the general idea is that the 90 days will be unified across Schengen and Gibraltar, and therefore any British citizen visiting Gibraltar will be limited to 90 days (as opposed to the current situation where you can stay as long as you want, Gibraltar doesn't care because you need a local residence permit to access public services). Spain will be responsible for checking this, and the controversial point is that if Spain refuses a British citizen entry, then they will have to return to the Gibraltarian passport control to decide on their next steps. It's assumed that they will be able to travel back to the UK, but no-one has really explained what will happen if Gibraltar accepts someone and Spain refuses them, or if they're wanted by Spain and not by Gibraltar.

The confusing part is that it's also not clear if British citizens will need the ETIAS or not to go to Gibraltar. If they will, it will cause a massive uproar, not least because Gibraltar won't be part of Schengen, but rather in a common travel area with Schengen.

I am always so surprised the UK and Ireland have never introduced a joint visa and immigration policy like the Schengen countries have. There has always been some nationalities that are visa free to go to the UK but require a visa to go to Ireland (but they can get around this by entering the UK first and then crossing in to Ireland). There has always been some nationalities that are visa free to go to Ireland but require a visa to go to the UK (but they can get around this by entering Ireland first and then crossing in to the UK). Then of course now Ireland offers a very easy way to avoid the ETA visa. Anyone who does not want an ETA can simply fly to Ireland and then cross in to the UK by land. So i kind it defeats the whole purpose of the UK introducing ETA when we have such an easy loophole to avoid it.

The simple answer here is that UK-Ireland relations were pretty terrible up until the mid 1990s, and there's still a lot of hostility towards the idea of allowing the UK to veto who enters/doesn't enter Ireland. In practice, both the UK and Ireland routinely refuse entry to anyone believed to be heading to the 'other' country without a visa, and they cooperate very closely on immigration-related matters.

With the ETA, it's correct that it's a bit of a mess. I can fly from Wrocław to Dublin using my Polish ID card, then I can go up to Belfast and over to GB without carrying or showing anyone my British passport. I wouldn't have the ETA, but I also wouldn't have any way of proving that I'm actually British beyond a Polish ID card that shows I was born in the UK. Yet, at the same time, I'm not obliged to carry ID when crossing from the RoI to NI according to the CTA rules. The only sensible thing is that the UK agreed that EU citizens resident in Ireland don't need an ETA if they have proof of living there, such as a driving licence.

A common visa/immigration policy would make sense, but how do you resolve the problem of EU citizens having freedom of movement to Ireland but not the UK?

 

[zero]

It's actually a bit more complicated than that. If you're Faroese or living in the Faroe Islands as a normal (mainland Europe) Danish citizen, you can pick between having a green Danish-Faroese passport, or a regular red Danish passport. The Danish passport is needed if you want to benefit from the EU's freedom of movement regulations, while the Danish-Faroese passport only allows you to live in Danish territories. It's the same with Greenland. They can't vote in EU elections as well.

It's worth pointing out that EU citizens can't just go and work in the Faroe Islands, they need a work permit. There are some other strange rules too, such as EU ID cards issued to non-Nordic citizens are not valid for obtaining a residence permit in the Faroe Islands, you need a passport.

In practice, the Faroese/Greenlandic passports are treated as normal Danish passports in the EU and so they have full FoM rights, probably because it would be too much hassle to actually differentiate between 'those with Faroese/Greenlandic passports who moved from the EU' and 'those who didn't move from the EU and therefore don't have the right to FoM'. Strictly speaking, holders of those passports should be asked to prove that they've been resident in Denmark first, but this is rarely/never asked for in practice, not least because the information page on the passport confirms them to be Danish citizens, only with two nationalities - Danish and Faroese.

The above is not correct; my previous post already stated the correct situation.

The choice between a Danish, Danish/Faroese and Danish/Greenlandic passport is merely cosmetic. All three versions of the passport confer the same rights to live in the EU and there is no need to move to Denmark first.

Citizens who were born on the Faroes and have never left can still choose to have the regular Danish passport. If there was a requirement to live in Denmark before being given EU rights, they wouldn't be allowed to obtain the regular Danish passport until they had moved to Denmark.

As the Faroes are not in the EU, it isn't strange that EU ID cards from non-Nordic countries are not accepted there.

When the UK was in the EU, British citizens connected with the Channel Islands and Isle of Man did not have EU freedom of movement unless they also had a connection to the UK, generally by birth, descent or 5 years' UK residence. This was recorded by means of an observation in their passports. If Denmark/the EU had wished to restrict the FoM rights of Danish citizens connected with the Faroes/Greenland (or the subset of Danish citizens connected with the Faroes/Greenland who also have no connection to Denmark), they could easily do something similar, but they have not done so.

 

[Cloud Strife]

The choice between a Danish, Danish/Faroese and Danish/Greenlandic passport is merely cosmetic. All three versions of the passport confer the same rights to live in the EU and there is no need to move to Denmark first.

Citizens who were born on the Faroes and have never left can still choose to have the regular Danish passport. If there was a requirement to live in Denmark before being given EU rights, they wouldn't be allowed to obtain the regular Danish passport until they had moved to Denmark.

It is not purely cosmetic, the green passports don't confer any rights to live in the EU. Danish citizens resident in the Faroes and Greenland don't have the right of freedom of movement, and they can't just move with their green passports from there into the EU. It's true that they can choose which passport they have, and the red passport gives them freedom of movement because no-one knows that they're resident in the Faroe Islands, but there is still a technical requirement for the green passport holders to move to Denmark first before they obtain the right to freedom of movement. Of course, in practice, they would just obtain a red Danish passport if they wanted to move somewhere outside of the Nordic Passport Union.

In short, the situation is like this:

- Danish nationals resident in the Faroe Islands are not regarded as having EU citizenship when their registered address is on the Faroe Islands, regardless of the colour of their passport.
- To get FoM, they need to first 'move' (even if it's only on paper) to European Denmark, which automatically gives them FoM.

If Denmark/the EU had wished to restrict the FoM rights of Danish citizens connected with the Faroes/Greenland (or the subset of Danish citizens connected with the Faroes/Greenland who also have no connection to Denmark), they could easily do something similar, but they have not done so.

They could have, but they chose to issue separate passports instead, which achieve the same purpose. In practice, because the information pages of those passports make it clear that the holder is a Danish citizen, they're treated as having EU FoM by some member states, even if they don't have it in practice. The green passports exist partially to make it clear that the Faroe Islands is not part of the EU FoM rules, and partially because there's no guarantee that the Faroese government won't change their mind in future on who has the right to stay there. They could, for instance, leave the Nordic Passport Union and Danish citizens from elsewhere in the Kingdom would have no right to stay there.

It should be pointed out that Faroese nationality is like Gibraltarian status, you can't just get it by being Danish and resident in the Faroe Islands, but rather you need to have a proven link to the islands, either through a period of residency or through having a Faroese parent.

It's a confusing situation, and I'm actually surprised that the EU hasn't demanded clarity on this matter. In practice, only green passports should be issued on the Faroe Islands, and those passports should make it clear that the Faroe Islands are not part of the EU.

As the Faroes are not in the EU, it isn't strange that EU ID cards from non-Nordic countries are not accepted there.

It is strange when you can travel there with your EU ID card, but you can't register to stay with it. North Cyprus has the same rule, incidentally.

 

[zero]

It is not purely cosmetic, the green passports don't confer any rights to live in the EU. Danish citizens resident in the Faroes and Greenland don't have the right of freedom of movement, and they can't just move with their green passports from there into the EU. It's true that they can choose which passport they have, and the red passport gives them freedom of movement because no-one knows that they're resident in the Faroe Islands, but there is still a technical requirement for the green passport holders to move to Denmark first before they obtain the right to freedom of movement. Of course, in practice, they would just obtain a red Danish passport if they wanted to move somewhere outside of the Nordic Passport Union.

In short, the situation is like this:

- Danish nationals resident in the Faroe Islands are not regarded as having EU citizenship when their registered address is on the Faroe Islands, regardless of the colour of their passport.
- To get FoM, they need to first 'move' (even if it's only on paper) to European Denmark, which automatically gives them FoM.

Please could you provide a source for these assertions, as it conflicts with what I was told by various officials and residents when I visited the Faroe Islands.

 

[stadler]

What is the status with the Aland Islands currently. As i understand they are in the EU but they still have a special status. People living in the Aland Islands also have their own passport just like the Faroe Islands and Greenland do. It is the same colour and design as the Finnish passport but just says "Aland" next to "Suomi" and "Finland" on the passport cover.

So are the Aland Islands joining the EES and ETIAS too. It is unclear whether they are officially in the Schengen currently. Aland Islands have no direct flights or ferries to outside the Schengen area so it is not as much of an issue. But they have an airport and seaport which are listed as official Schengen entry points so you can enter via private aeroplane or private ferry from outside the Schengen area.

Monaco is another one. Monaco is also listed as an official Schengen entry point at their seaport and heliport. Apparently there are some wealthy people with private boats and private helicopters who enter Monaco from outside the Schengen area. It is unclear whether EES and ETIAS will apply here considering that Monaco is not a Schengen member but has an open border.

Andorra and San Marino also have open borders despite not being Schengen members but they do not have any airports so it is impossible to enter them without going to a Schengen country first. This creates some weird oddities. San Marino gives visa free access to Russian and Kazakh and Kenyan and Chinese citizens but yet it is impossible for those people to take advantage of this as they require a Schengen visa in order to get there. Andorra gives visa free access to Russian and Kazakh citizens but yet it is impossible for those people to take advantage of this as they require a Schengen visa in order to get there. So on paper a Russian can go to Andorra and San Marino with no visa but it means nothing as they need a Schengen visa to get there.

I am always surprised why Monaco and San Marino and Andorra never officially joined the Schengen area. They are basically in the Schengen in everything but name. Liechtenstein is a very similar style microstate and they have officially joined the Schengen area.

 

[Cloud Strife]

Please could you provide a source for these assertions, as it conflicts with what I was told by various officials and residents when I visited the Faroe Islands.

Sure, it's here: https://www.logting.fo/logtingsmal/...ispurningar/100-06 Fyrispurningur um pass.htm

This is from the Faroese Minister of Justice, in particular:

In relation to the provisions of the EC Treaty on the free movement of persons, there is no difference in the legal status of Faroese people who choose a passport issued on a standard passport form (EU passport) and Faroese people who choose a passport issued on a special Faroese passport form.

Danish citizens residing in the Faroe Islands are not covered by the personal scope of the EC Treaty. This means that they cannot rely on the rules on the free movement of persons. In this context, it makes no difference whether the person concerned is in possession of an EU passport or whether it is a passport issued on a special Faroese passport form.

Danish citizens who are resident in Denmark at the time they wish to rely on EU law have the opportunity to rely on the rules on free movement of persons. In this context, it makes no difference whether the person concerned holds an EU passport or a passport issued on a special Faroese passport form.​

It's the place of residence that counts, but of course, there's nothing on the red Danish passports to suggest that the holder isn't entitled to FoM.
​

What is the status with the Aland Islands currently. As i understand they are in the EU but they still have a special status. People living in the Aland Islands also have their own passport just like the Faroe Islands and Greenland do. It is the same colour and design as the Finnish passport but just says "Aland" next to "Suomi" and "Finland" on the passport cover.

So, this is where Nordic constitutional theory gets a bit strange:

- Aland joined Schengen by virtue of being members of the EU, which they voted for. Had they voted against EU membership, then they would have had the same status as the Faroes today.
- The Faroes chose to stay out of the EU, hence they had/have no obligation to join Schengen
- Both Aland and the Faroes joined the Nordic Passport Union by virtue of being autonomous territories within the signatory states, that is, Finland and the Kingdom of Denmark.

So are the Aland Islands joining the EES and ETIAS too. It is unclear whether they are officially in the Schengen currently. Aland Islands have no direct flights or ferries to outside the Schengen area so it is not as much of an issue. But they have an airport and seaport which are listed as official Schengen entry points so you can enter via private aeroplane or private ferry from outside the Schengen area.

Aland is very much in Schengen and covered by the EES/ETIAS. Their passport control is carried out by the Finnish Border Guard, and for the purposes of passport control, Aland is exactly the same as any other Schengen member. The only difference is with residency, but that isn't connected to passport control.

In the Faroes, the border control is carried out by the Danish police, as the Faroe Islands haven't 'taken over' policing yet. They can, but the Faroese government has a policy of slowly repatriating powers rather than doing it all in one go, as they don't have the administrative capability.

Monaco is another one. Monaco is also listed as an official Schengen entry point at their seaport and heliport. Apparently there are some wealthy people with private boats and private helicopters who enter Monaco from outside the Schengen area. It is unclear whether EES and ETIAS will apply here considering that Monaco is not a Schengen member but has an open border.

Monaco's border crossings are controlled by the Police aux Frontieres, and so the EES/ETIAS applies as if Monaco was part of France. Generally speaking, Monaco more or less gives France a veto over who can go there, as the alternative would be France imposing border control on Monaco.

Andorra and San Marino also have open borders despite not being Schengen members but they do not have any airports so it is impossible to enter them without going to a Schengen country first.

Point of order: Andorra does not have an open border. There are controls by both France/Spain and Andorra at the border crossings, and it's illegal to enter Schengen outside of those border crossings. There are some unguarded crossings, but both Andorra and France/Spain do patrol them. What should be said is that Andorra doesn't have a visa policy: if you can get to Andorra, you don't need a visa to enter. The Russian/Kazakh agreements you refer to are bilateral agreements so that Andorrans can visit those countries without a visa, while also formalising the lack of a visa for those nationals to visit Andorra. It's actually not an uncommon situation for Schengen visa visitors to Andorra to be informed at the border by the Spanish/French police that they won't be able to return if they hold a single entry Schengen visa.

There are some problems caused by this, as for example, someone who needs a visa for Schengen and resident in Andorra cannot move into Schengen countries without a visa, and it's not possible to obtain one in Andorra. In practice, Spain (I'm not sure about France) issues 3 year multiple-entry visas to those with Andorran residence permits, so it's not a major deal. I believe that the EU and Andorra are currently negotiating on this, so that France/Spain will have veto power over the issuing of Andorran residence permits, but in return, those residence permits will be treated in the same way as any other EU/EEA/CH residence permit for the purpose of border control.

What the EU is trying to do is move towards the same system as with Monaco, where there's a veto by the neighbouring state over the issuing of a residence permit, and in return, those residence permits will be valid for travel within the EU. Monaco in particular has an interesting system: you need a visa for Schengen (or EU freedom of movement) to be able to apply for a residence permit there. If you don't have one, then you need to get permission from the French embassy in Monaco before applying for a residence permit. So, an American that wants to get a residence permit from Monaco must first have a long term French visa before Monaco will allow them to apply for a residence permit there.

San Marino on the other hand doesn't have border control with Italy and the border is fully open, and they also don't have visas, only residence permits.

I am always surprised why Monaco and San Marino and Andorra never officially joined the Schengen area. They are basically in the Schengen in everything but name. Liechtenstein is a very similar style microstate and they have officially joined the Schengen area.

Monaco doesn't need to, as France pretty much handles all of the Schengen-related stuff for them anyway. They could join, but as France controls her exterior borders, there's little benefit to actually joining on paper beyond pointless bureaucracy.

San Marino on the other hand could, but they're very much not keen on the topic as it would require implementing EU laws, something that they really don't want to do. The EU is trying to solve this issue through a bespoke agreement, just like with Andorra. As for why Andorra never joined, the simple answer is that they didn't want to follow the EU's common visa rules. It would have required them to issue visas and to deal with all the administrative formalities involving getting France/Spain to issue those visas, when staying outside Schengen was simply easier as they only have to station a few border police at the border crossings. It's really more of a problem for France/Spain than for Andorra.

Liechtenstein on the other hand joined because they already had border control in place with Austria, and they really didn't want to set up border controls with Switzerland. After Switzerland joined, controls still existed on the Liechtenstein border in theory until 2011, with physical police controls replaced with cameras and other forms of monitoring the border. Again though, Liechtenstein is in a customs union with Switzerland, whereas Andorra isn't in any sort of customs union with France or Spain.

 

[stadler]

Sure, it's here: https://www.logting.fo/logtingsmal/logtingsmal00/skrivligir fyrispurningar/100-06 Fyrispurningur um pass.htm

This is from the Faroese Minister of Justice, in particular:

It's the place of residence that counts, but of course, there's nothing on the red Danish passports to suggest that the holder isn't entitled to FoM.
​

So, this is where Nordic constitutional theory gets a bit strange:

- Aland joined Schengen by virtue of being members of the EU, which they voted for. Had they voted against EU membership, then they would have had the same status as the Faroes today.
- The Faroes chose to stay out of the EU, hence they had/have no obligation to join Schengen
- Both Aland and the Faroes joined the Nordic Passport Union by virtue of being autonomous territories within the signatory states, that is, Finland and the Kingdom of Denmark.



Aland is very much in Schengen and covered by the EES/ETIAS. Their passport control is carried out by the Finnish Border Guard, and for the purposes of passport control, Aland is exactly the same as any other Schengen member. The only difference is with residency, but that isn't connected to passport control.

In the Faroes, the border control is carried out by the Danish police, as the Faroe Islands haven't 'taken over' policing yet. They can, but the Faroese government has a policy of slowly repatriating powers rather than doing it all in one go, as they don't have the administrative capability.



Monaco's border crossings are controlled by the Police aux Frontieres, and so the EES/ETIAS applies as if Monaco was part of France. Generally speaking, Monaco more or less gives France a veto over who can go there, as the alternative would be France imposing border control on Monaco.



Point of order: Andorra does not have an open border. There are controls by both France/Spain and Andorra at the border crossings, and it's illegal to enter Schengen outside of those border crossings. There are some unguarded crossings, but both Andorra and France/Spain do patrol them. What should be said is that Andorra doesn't have a visa policy: if you can get to Andorra, you don't need a visa to enter. The Russian/Kazakh agreements you refer to are bilateral agreements so that Andorrans can visit those countries without a visa, while also formalising the lack of a visa for those nationals to visit Andorra. It's actually not an uncommon situation for Schengen visa visitors to Andorra to be informed at the border by the Spanish/French police that they won't be able to return if they hold a single entry Schengen visa.

There are some problems caused by this, as for example, someone who needs a visa for Schengen and resident in Andorra cannot move into Schengen countries without a visa, and it's not possible to obtain one in Andorra. In practice, Spain (I'm not sure about France) issues 3 year multiple-entry visas to those with Andorran residence permits, so it's not a major deal. I believe that the EU and Andorra are currently negotiating on this, so that France/Spain will have veto power over the issuing of Andorran residence permits, but in return, those residence permits will be treated in the same way as any other EU/EEA/CH residence permit for the purpose of border control.

What the EU is trying to do is move towards the same system as with Monaco, where there's a veto by the neighbouring state over the issuing of a residence permit, and in return, those residence permits will be valid for travel within the EU. Monaco in particular has an interesting system: you need a visa for Schengen (or EU freedom of movement) to be able to apply for a residence permit there. If you don't have one, then you need to get permission from the French embassy in Monaco before applying for a residence permit. So, an American that wants to get a residence permit from Monaco must first have a long term French visa before Monaco will allow them to apply for a residence permit there.

San Marino on the other hand doesn't have border control with Italy and the border is fully open, and they also don't have visas, only residence permits.



Monaco doesn't need to, as France pretty much handles all of the Schengen-related stuff for them anyway. They could join, but as France controls her exterior borders, there's little benefit to actually joining on paper beyond pointless bureaucracy.

San Marino on the other hand could, but they're very much not keen on the topic as it would require implementing EU laws, something that they really don't want to do. The EU is trying to solve this issue through a bespoke agreement, just like with Andorra. As for why Andorra never joined, the simple answer is that they didn't want to follow the EU's common visa rules. It would have required them to issue visas and to deal with all the administrative formalities involving getting France/Spain to issue those visas, when staying outside Schengen was simply easier as they only have to station a few border police at the border crossings. It's really more of a problem for France/Spain than for Andorra.

Liechtenstein on the other hand joined because they already had border control in place with Austria, and they really didn't want to set up border controls with Switzerland. After Switzerland joined, controls still existed on the Liechtenstein border in theory until 2011, with physical police controls replaced with cameras and other forms of monitoring the border. Again though, Liechtenstein is in a customs union with Switzerland, whereas Andorra isn't in any sort of customs union with France or Spain.

Thank you for the information. That is very insightful and answers a lot of my questions. These matters can get so confusing.

Aland is an interesting one as it is the only one of these special autonomous territories that joined the EU fully. Looking in to it i notice that Aland is excluded from the EU tax union. So it looks like they got given some special exemptions which may explain why they joined.

I am surprised that Monaco is happy with allowing France to control their borders posts. Even in the official Schengen countries they never let another country control their entry points. I wonder if there are any special regulations. So could a French border guard simply refuse someone at the seaport or heliport in Monaco (like they could at any French border) or do they at least have to consult with the Monaco authorities first before refusing entry and sending someone back.

Andorra still kind of has an open border. I have been four times and crossed both the French and Spanish borders and never been stopped by the Andorran or French or Spanish officers. They have officers at the border points and you drive through border posts and customs posts (and you can optionally stop if you want to get your Schengen entry and exit stamps from the French and Spanish border guards) but i have never been stopped. I have heard that they sometimes stop people so maybe they just do random checks. But they are definitely not stopping everyone and most people seem to just drive straight through without any checks.

San Marino actually had a referendum on EU membership back in 2013 and they surprisingly voted in favour in joining. It was not enacted as the turnout was too low (a minimum of 1/3 of registered voters must vote for any referendum in San Marino to be valid) but it does show that San Marino seems to be more happy with the EU laws than you would have thought. So maybe in the future they will join Schengen officially.

I do not understand is why countries like Monaco (and Andorra which you mention is negotiating a similar deal) would rather give veto power of residence permits rather than become a full official Schengen member? Why are they happy to give so much control to neighbouring contries over residence permits for their own country? If they properly joined Schengen then they would be able to fully control residence permits and visas in the same way that all other Schengen countries do. Surely having to issue visas and the administration that comes with it is better than letting another country have veto power over residence permits. So this means that Monaco could be perfectly happy to issue a residence permit but then France has an issue with it and decides to veto it. I wonder how often these kind of issues come up.

Also you mentioned that Faroe Islands residents can chose to get a normal Danish passport? Are you sure that is definitely still the case today? From what i have been told it is only Greenland residents that can choose which passport they want to get. If you apply from Greenland then you get a choice of a standard Danish one or a Greenlandic one. But anyone applying from the Faroe Islands automatically gets a green Faroe Islands passport without being given any option to chose which type. I have just checked the Faroese passport application form now and there is no option to request a standard Danish passport so i have doubts whether you can still choose.

 

[signed]

Why are they happy to give so much control to neighbouring contries over residence permits for their own country?

You can't* get into Andorra, Monaco or San Marino without passing through Italy, France or Spain and residence permits are national law matters (not EU law). No need to duplicate things that don't need duplicating.

Take an example of Monaco, if France doesn't like a visitor to Monaco right now they just don't issue the visa and that's it

If Monaco was a full member of the Schengen area then they would maybe issue a visa but that visa would probably be a Limited Territoriality Visa prohibiting entry into France, the only way in or out of Monaco would then be to charter an helicopter or a boat from Italy and that's if Italy wants them, that's basically at the same point of that visitor can't physically get to Monaco though. You won't be able to do sterile transit in Nice airport either as neither EU law nor France realistically would allow it.

And that's not counting creating a border unit from scratch, dealing with issuing visas, having to make agreements with countries embassies abroad...

 

[Howardh]

It would be good if the UK and the Schengen area could make an agreement where UK citizens do not require an ETIAS visa and in return Schengen citizens do not require an ETA visa. It would make so much sense considering that we are neighbours. It would be good if this could be considered maybe as part of some wider deal between the UK and the Schengen countries.

I agree totally, however airports in the EU which are mostly tourist entry points from UK have spent an awful lot of money setting the machines up, so won't be best happy if such a deal is made and they become mostly redundant!

But it is bonkers that we don't have a return agreement where we just show our UK passports, and EU's coming here show their passport or ID, and both parties are un-time restricted as long as we/they can afford their stay and are fully insured (insurance should also be checked - randomly - at points of entry). If visitors are on a wanted list, we could arrest them on entry, as we will under then new systems.

It just needs a party that's brave enough to unbrexit one of the worst parts of it.

 

[Cloud Strife]

Aland is an interesting one as it is the only one of these special autonomous territories that joined the EU fully. Looking in to it i notice that Aland is excluded from the EU tax union. So it looks like they got given some special exemptions which may explain why they joined.

Yes, this is all because of the tax free sales onboard ships. To cut a long story short, Aland's economy is largely based on shipping, with Viking Line (one of the largest Baltic ferry companies) being registered in Mariehamn. Before 1999 (when duty free sales were banned on intra-EU journeys), the ships sailing between Sweden and Finland still stopped in Aland, because it meant they could offer duty free sales on Aland-Finland trips as well as on Sweden-Aland and Sweden-Finland trips. But let's go back...

Aland was very much against joining the EU, because it would have meant an end to the duty free trips, and so the island's shipping industry would have probably been lost. As a result, a kind of legal fiction was created where Aland would remain outside of the EU customs area, but in practice, they are completely aligned with the EU customs/tax rules, it's just that they're officially outside, meaning duty free sales could continue. So, if you sell something to Aland, you don't charge VAT, but Aland Post or whoever delivers it will charge Aland VAT, which is just so coincidentally at the exact same amount as Finnish VAT. Things like customs/excise duties are also at exactly the same rate, and Finland's government handles the collection of these duties, just as they do in mainland Finland.

There were some other things associated with the EU referendum there, such as restrictions on non-Alanders buying land, but the shipping was the big one. The EU agreed quite quickly to these concessions as part of the negotiation process, and there were already plenty of examples from elsewhere (The Canary Islands, the Crown Dependencies, Gibraltar, Ceuta/Melilla etc) so adding one more for the sake of Aland's economy and the Baltic sea links wasn't much of a problem.

It's largely legal nonsense, but it was permitted because Aland was given autonomy by the League of Nations, and they are guaranteed to be politically neutral. Of course, they have their own parliament and they control many of the things that are normally handled by the Finnish government, but Aland is politically an integral part of Finland, unlike our Crown Dependencies or the Faroes/Greenland which are part of the Danish Realm but not part of Denmark.

One fun and interesting fact is that Aland's own ferry company, Alandstrafiken, doesn't offer duty free sales on ferries between Aland and Finland proper. I'm not really sure why, but I believe it's essentially down to the fact that Finland has agreed with Aland not to offer duty free sales on shorter routes. They could offer it, and certainly nothing stops them.

I am surprised that Monaco is happy with allowing France to control their borders posts. Even in the official Schengen countries they never let another country control their entry points. I wonder if there are any special regulations. So could a French border guard simply refuse someone at the seaport or heliport in Monaco (like they could at any French border) or do they at least have to consult with the Monaco authorities first before refusing entry and sending someone back.

As I understand it, Monaco can (but often doesn't) take part in these checks, but in practice, it's left entirely up to the French PAF to decide. The background of this is from the "Convention of Good Neighbourliness" of 1963, where Monaco agreed to align their immigration policies with those of France. You can find it here: https://www.vertic.org/media/Nation...MC_Convention_Good-Neighbourliness_France.pdf

It's largely a pragmatic move on their part, because otherwise they would have to maintain border controls with France. The background of this treaty comes from 1962, where France imposed passport and customs controls on Monaco as Monaco had been...let's say "unfriendly" in terms of taxation policies. The French more or less agreed to let Monaco continue their low tax regime in exchange for various concessions regarding control over Monaco's immigration policies.

Andorra still kind of has an open border. I have been four times and crossed both the French and Spanish borders and never been stopped by the Andorran or French or Spanish officers. They have officers at the border points and you drive through border posts and customs posts (and you can optionally stop if you want to get your Schengen entry and exit stamps from the French and Spanish border guards) but i have never been stopped. I have heard that they sometimes stop people so maybe they just do random checks. But they are definitely not stopping everyone and most people seem to just drive straight through without any checks.

With the Andorran border, the police checks are really just cursory, because the real focus is on customs issues. The French and Spanish tend to stop those who don't look European, but it's very rare to hear of Andorra stopping anyone unless it's for training purposes. It does cause problems, because people aren't aware that a single entry Schengen visa is cancelled upon leaving Schengen at the Andorran border, although I've heard that in practice, the French and Spanish police tend to just lecture the person if it's obvious that they're a clueless tourist. Having said that, with the EES, they will have to systematically start stopping everyone unless an agreement is reached with Andorra. In practice, I'd expect them to wave through anyone with an EU or Andorran ID card/passport, but time will tell.

It's actually an interesting problem, because Schengen rules already require everyone to be scanned in and out of the Schengen area, but it's simply ignored by both the French and Spanish authorities.

I do not understand is why countries like Monaco (and Andorra which you mention is negotiating a similar deal) would rather give veto power of residence permits rather than become a full official Schengen member? Why are they happy to give so much control to neighbouring contries over residence permits for their own country? If they properly joined Schengen then they would be able to fully control residence permits and visas in the same way that all other Schengen countries do. Surely having to issue visas and the administration that comes with it is better than letting another country have veto power over residence permits. So this means that Monaco could be perfectly happy to issue a residence permit but then France has an issue with it and decides to veto it. I wonder how often these kind of issues come up.

I think it's just about being pragmatic, nothing more. The microstates (and Gibraltar) control migration through the issuing of residence permits rather than through border controls, and there's really no threat to them from irregular migration. I think they're also not really bothered about it if someone is deemed undesirable in Schengen, as it means that they're likely to cause trouble in their countries too. Perhaps there might be a handful of situations where someone could be on good terms with the government and yet they're incredibly dodgy, but how often will such situations arise?

== Doublepost prevention - post automatically merged: 27 Jul 2025 ==

It just needs a party that's brave enough to unbrexit one of the worst parts of it.

The entire thing is unbelievably stupid. The UK and EU would both be stronger by having a common digital entry permission system, as why would we want someone that isn't wanted in the EU?

In terms of duration of stay, I still don't understand why the UK hasn't negotiated a longer period with the EU. EU citizens can come to the UK for 6 months, so why hasn't the UK obtained the same for British citizens in the EU?

 

[island]

The entire thing is unbelievably stupid. The UK and EU would both be stronger by having a common digital entry permission system, as why would we want someone that isn't wanted in the EU?

The UK has stricter requirements as respects criminal records.

 

[AlastairFraser]

Andorra and San Marino also have open borders despite not being Schengen members but they do not have any airports so it is impossible to enter them without going to a Schengen country first

Although Andorra has helipads, which can be reached from other non-EU countries I believe.

 

[signed]

Although Andorra has helipads, which can be reached from other non-EU countries I believe.

I wonder if there any helicopters with the range to travel from the UK or North Africa to Andorra?

 

[stadler]

Although Andorra has helipads, which can be reached from other non-EU countries I believe.

I wonder if there any helicopters with the range to travel from the UK or North Africa to Andorra?

It also depends on whether Andorra allows helicopters to and from outside the Schengen area to land and takeoff at their three heliports. They may well restrict it to only allowing flights to and from the Schengen area due to the lack of border control. But i can not find anything online confirming.

San Marino also has a small airport for small private aircraft. So technically you could probably reach there from outside the Schengen area. But again i am not sure if San Marino allows flights to and from outside the Schengen area to land and take off at their airport.

I do not think Andorra or San Marino even have their own border officers so i am not sure it would even be possible. They do not yet have a Monaco style agreement allowing French or Spanish or Italian officers to do border control. I would be interested to know more if anyone can find confirmation but i suspect the three heliports in Andorra and the airport in San Marino are likely restricted to flights to and from the Schengen area only.

 

[AlastairFraser]

I wonder if there any helicopters with the range to travel from the UK or North Africa to Andorra?

Cami Heliport in La Massana is approx. 420 miles straight line distance from Algiers airport, and there are plenty of helicopters in existence that have a range of 500+ miles.

San Marino also has a small airport for small private aircraft. So technically you could probably reach there from outside the Schengen area. But again i am not sure if San Marino allows flights to and from outside the Schengen area to land and take off at their airport.

San Marino doesn't - "It is not possible to reach the airstrip directly from non-Schengen countries without completing customs checks at an authorized Italian airport/airstrip. Direct departures from LIKD to non-Schengen countries are prohibited ."
The above quote was taken from the Sammarinese Aero Club website here: https://aeroclubsanmarino.com/come-arrivare-in-volo/

Andorra is less clear, I can't find a definitive answer. I think a chartered helicopter from a non-Schengen country would be possible with advance permission.

 

[signed]

I do not think Andorra or San Marino even have their own border officers so i am not sure it would even be possible.

Andorra does have their own border controls

 

[stadler]

Cami Heliport in La Massana is approx. 420 miles straight line distance from Algiers airport, and there are plenty of helicopters in existence that have a range of 500+ miles.

San Marino doesn't - "It is not possible to reach the airstrip directly from non-Schengen countries without completing customs checks at an authorized Italian airport/airstrip. Direct departures from LIKD to non-Schengen countries are prohibited ."
The above quote was taken from the Sammarinese Aero Club website here: https://aeroclubsanmarino.com/come-arrivare-in-volo/

Andorra is less clear, I can't find a definitive answer. I think a chartered helicopter from a non-Schengen country would be possible with advance permission.

Thank you for that website link. That makes sense as i suppose it means that San Marino does not have to worry about border control or employ immigration officers. Interestingly i see they have both an airport and a heliport there.

It is difficult to find anything regarding the Andorra regulations. I tried searching in Catalan too. If they do allow helicopters from outside the Schengen then that means that some nationalities could potentially get in to the Schengen area without a visa. The citizens of Russia and Kazakhstan could fly by private helicopter to Andorra and then cross by land in to the Schengen and spend months travelling around the Schengen area. Then when they want to leave they could just cross back to Andorra and fly back again. So i would be surprised if they allowed this as this effectively creates a loophole. They rarely stop cars when crossing to and from Andorra so you effectively get open borders to the Schengen area.

Maybe they do indeed allow helicopters from outside the Schengen area. The amount of people wealthy enough to fly by private helicopter from outside the Schengen area to Andorra is probably very low so maybe they are not worried. There are a lot of millionaires who live there but a helicopter that distance must be extortionate.

Andorra does have their own border controls

Do they actually have immigration officers. I know the border has some French and Spanish officers but i am not sure whether the Andorra officers at their checkpoint are actual immigration officers or just customs officers. Andorra does not even have passport stamps and does not issue any visas so i have doubts whether they actually have immigration officers or just customs officers.

 

[AlastairFraser]

Thank you for that website link. That makes sense as i suppose it means that San Marino does not have to worry about border control or employ immigration officers. Interestingly i see they have both an airport and a heliport there.

It is difficult to find anything regarding the Andorra regulations. I tried searching in Catalan too. If they do allow helicopters from outside the Schengen then that means that some nationalities could potentially get in to the Schengen area without a visa. The citizens of Russia and Kazakhstan could fly by private helicopter to Andorra and then cross by land in to the Schengen and spend months travelling around the Schengen area. Then when they want to leave they could just cross back to Andorra and fly back again. So i would be surprised if they allowed this as this effectively creates a loophole. They rarely stop cars when crossing to and from Andorra so you effectively get open borders to the Schengen area.

Maybe they do indeed allow helicopters from outside the Schengen area. The amount of people wealthy enough to fly by private helicopter from outside the Schengen area to Andorra is probably very low so maybe they are not worried. There are a lot of millionaires who live there but a helicopter that distance must be extortionate.

Perhaps, I think it's probably done on a case by case basis. I would think the the Andorran government reports the entry of non-EU citizens by helicopter to their neighbours anyway, so someone intending to enter the Schengen area illegally this way would be caught very quickly.

Do they actually have immigration officers. I know the border has some French and Spanish officers but i am not sure whether the Andorra officers at their checkpoint are actual immigration officers or just customs officers. Andorra does not even have passport stamps and does not issue any visas so i have doubts whether they actually have immigration officers or just customs officers.

The Andorran Police has a Borders Unit that is assigned to deal with customs and immigration responsibilities.

 

[m0ffy]

I am surprised that Monaco is happy with allowing France to control their borders posts. Even in the official Schengen countries they never let another country control their entry points. I wonder if there are any special regulations. So could a French border guard simply refuse someone at the seaport or heliport in Monaco (like they could at any French border) or do they at least have to consult with the Monaco authorities first before refusing entry and sending someone back.

It would be underselling it to describe the relationship between France and Monaco as close. Constitutionally, Monaco agrees to work in the French interest economically and politically in exchange for a guarantee of its sovereignty (which it also promises to use in the interest of the French Republic).

 

[D6130]

It would be underselling it to describe the relationship between France and Monaco as close. Constitutionally, Monaco agrees to work in the French interest economically and politically in exchange for a guarantee of its sovereignty (which it also promises to use in the interest of the French Republic).

....and of course, should the Crown Prince fail to produce a male heir, the principality will return by default to France.

 

[Full Standing]

Andorra does not even have passport stamps

I think they have, but passports are not stamped by default. However, if you wish to get a stamp on entry (e.g. because you like collecting passport stamps), you can ask at the border and your passport will be stamped. At least that's what many travellers reported online. Getting a stamp on exit seems harder though.

Edit (thanks to stadler): These stamps are only souvenirs, not proper immigration stamps.

 

[stadler]

I think they have, but passports are not stamped by default. However, if you wish to get a stamp on entry (e.g. because you like collecting passport stamps), you can ask at the border and your passport will be stamped. At least that's what many travellers reported online. Getting a stamp on exit seems harder though.

Andorra has a fake passport stamp that is intended as a souvenir. It does not even have the date on it. It is not a real passport stamp. Andorra, Liechtenstein, Monaco, San Marino, all issue these souvenir stamps. The ones in Liechtenstein and Monaco and San Marino are issued at tourist information offices and have the date but are still not official stamps. The one in Andorra is issued on request at the border office but does not even have a date on it. It is solely intended as a souvenir and is not an actual immigration stamp.

I would strongly advise against getting one of these. There has been cases of people being refused entry to countries due to having these souvenir micronation stamps. Andorra, Liechtenstein, Monaco, San Marino, passport stamps can be considered by some countries to be defacing a passport because you are stamping it with an unofficial stamp that is not intended for immigration purposes. If you want one then get it on a blank piece of paper.

As far as i am aware Andorra has no proper passport stamps. I have not seen any evidence of one and i was told that they do not exist. France and Spain both issue standard Schengen passport stamps at the Andorra border on request but Andorra has none. I think that Andorra may have had official passport stamps decades ago but certainly nothing these days.

 

[Cloud Strife]

Do they actually have immigration officers. I know the border has some French and Spanish officers but i am not sure whether the Andorra officers at their checkpoint are actual immigration officers or just customs officers. Andorra does not even have passport stamps and does not issue any visas so i have doubts whether they actually have immigration officers or just customs officers.

Andorra has border police. They're visible on Street View, called the "Grup de Fronteres", part of the "Unitat de Fronteres i Estrangeria". Normally there's three on duty at every border crossing during every shift, usually two in the booths and a supervising officer in the office. There's also an image from the new border crossing on the French border here, showing the Andorran border police.

I would be interested to know more if anyone can find confirmation but i suspect the three heliports in Andorra and the airport in San Marino are likely restricted to flights to and from the Schengen area only.

Andorra has border control at the heliports, but flights are only permitted to/from airports with border crossing facilities. Most people fly to Barcelona, but there's also an additional restriction: you can't fly to Andorra without having the ability to enter either France or Spain. So, let's assume you're a wealthy Russian that wants to fly from North Africa to Andorra. You can do it, but Andorra won't let you into the country unless you have at least a valid single entry visa for the Schengen countries. There is actually a complication at the minute with the new heliport, as the Andorran Government wants to have commercial helicopter flights from the new heliport to Andorra-La Seu d'Urgell and then an onwards flight to Madrid, but it requires the Generalitat de Catalunya to organise border control there which it doesn't currently have.

Andorra has a fake passport stamp that is intended as a souvenir.

It's not fake. The stamp given by Andorra is an entirely legitimate entry stamp, it just looks a bit rubbish.

I would strongly advise against getting one of these.

The Sammarinese stamp is perfectly legitimate as well, it's only the Monaco one that isn't official. Actually, the one in San Marino even requires an official tax stamp, and it's recognised by their government as official.

Speaking of stamps, I'm glad to have managed to get a Gibraltar stamp in my passport. It's quite difficult to get, and I was fortunate enough to have crossed the border on foot behind some people from Hong Kong who needed to get their passports stamped.

== Doublepost prevention - post automatically merged: 27 Jul 2025 ==

I think they have, but passports are not stamped by default. However, if you wish to get a stamp on entry (e.g. because you like collecting passport stamps), you can ask at the border and your passport will be stamped. At least that's what many travellers reported online. Getting a stamp on exit seems harder though.

Andorra generally won't stamp on exit, only on entry, as these are entry stamps. The reason why they don't have dates is because anyone who needs the stamp will have a corresponding exit stamp from either France or Spain, so there's no reason for them to duplicate it. Andorra did have entry stamps in the past with dates, but they got rid of them years ago, probably because there was absolutely no reason for them to exist after Spain restored democracy.

 

[stadler]

Andorra has border police. They're visible on Street View, called the "Grup de Fronteres", part of the "Unitat de Fronteres i Estrangeria". Normally there's three on duty at every border crossing during every shift, usually two in the booths and a supervising officer in the office. There's also an image from the new border crossing on the French border here, showing the Andorran border police.



Andorra has border control at the heliports, but flights are only permitted to/from airports with border crossing facilities. Most people fly to Barcelona, but there's also an additional restriction: you can't fly to Andorra without having the ability to enter either France or Spain. So, let's assume you're a wealthy Russian that wants to fly from North Africa to Andorra. You can do it, but Andorra won't let you into the country unless you have at least a valid single entry visa for the Schengen countries. There is actually a complication at the minute with the new heliport, as the Andorran Government wants to have commercial helicopter flights from the new heliport to Andorra-La Seu d'Urgell and then an onwards flight to Madrid, but it requires the Generalitat de Catalunya to organise border control there which it doesn't currently have.



It's not fake. The stamp given by Andorra is an entirely legitimate entry stamp, it just looks a bit rubbish.



The Sammarinese stamp is perfectly legitimate as well, it's only the Monaco one that isn't official. Actually, the one in San Marino even requires an official tax stamp, and it's recognised by their government as official.

Speaking of stamps, I'm glad to have managed to get a Gibraltar stamp in my passport. It's quite difficult to get, and I was fortunate enough to have crossed the border on foot behind some people from Hong Kong who needed to get their passports stamped.

== Doublepost prevention - post automatically merged: 27 Jul 2025 ==



Andorra generally won't stamp on exit, only on entry, as these are entry stamps. The reason why they don't have dates is because anyone who needs the stamp will have a corresponding exit stamp from either France or Spain, so there's no reason for them to duplicate it. Andorra did have entry stamps in the past with dates, but they got rid of them years ago, probably because there was absolutely no reason for them to exist after Spain restored democracy.

Thank you for the information. So it sounds like Andorra are practically enforcing Schengen anyway (if they require a Schengen visa when arriving from outside the area) despite not being a Schengen member. So if someone was to land in Andorra in a private helicopter (from outside the Schengen area) without a Schengen visa then i presume they would be refused entry and turned around and sent back. I wonder if there is an exception for prople that have Andorra residence permits or if they would still need a Schengen visa too.

They may be official stamps in that they are issued by a government office or recognised by the government but i do not think that they are considered immigration stamps. Their sole purpose is as souvenirs for tourists. All of these micronation stamps have zero use as actual immigration stamps and they are not used for immigration purposes to track visits to the country. So even though they are official i would still debate whether they are proper passport stamps or just official souvenir stamps.

Speaking of Gibraltar i wonder what is happening with stamps now this new agreement has been signed. I am presuming that the UK and Spanish land border posts will be shut (and as a result no stamps will be issued by UK or Spanish officers at the land border any more) and the Spanish immigration officers will now issue Schengen stamps at the airport with "Gibraltar" as the entry and exit place name. But it is not clear if UK border officers will continue issuing their own stamps at the airport too. So potentially some people may get two sets of passport stamps (from both Spanish and UK immigration officers) when arriving at the airport.

 

[Cloud Strife]

Thank you for the information. So it sounds like Andorra are practically enforcing Schengen anyway (if they require a Schengen visa when arriving from outside the area) despite not being a Schengen member. So if someone was to land in Andorra in a private helicopter (from outside the Schengen area) without a Schengen visa then i presume they would be refused entry and turned around and sent back. I wonder if there is an exception for prople that have Andorra residence permits or if they would still need a Schengen visa too.

Yes, although if you have an Andorran residence permit, you'd be admitted. The general idea is that by doing this, the Schengen members bordering Andorra can get away with a light touch border regime for the control of people, so it's in Andorra's best interest to do this. Of course, Andorra could let them in, but what would be the point in disturbing relations with France and Spain for a handful of people at most?

Speaking of Gibraltar i wonder what is happening with stamps now this new agreement has been signed. I am presuming that the UK and Spanish land border posts will be shut (and as a result no stamps will be issued by UK or Spanish officers at the land border any more) and the Spanish immigration officers will now issue Schengen stamps at the airport with "Gibraltar" as the entry and exit place name. But it is not clear if UK border officers will continue issuing their own stamps at the airport too. So potentially some people may get two sets of passport stamps (from both Spanish and UK immigration officers) when arriving at the airport.

From what I understand:

- Spain will register the traveller in the EES, so they will get a 'digital' stamp.
- Gibraltar may or may not stamp them into Gibraltar, although it's possible that they will start doing it to track the 90 days as they won't have access to the EES records. They already regularly stamp passports of non-British/EU travellers on arrival at the airport and sea port, and they do stamp some passports at the land frontier.
- It's not UK border officers in Gibraltar, but the Gibraltarian Borders and Coastguards Agency.

If Spain does somehow still have stamps by the time this agreement is implemented (it won't be anytime soon, because they'll need to build the extension to the airport first), then it's likely that people will receive a stamp with La Linea de la Concepción rather than Gibraltar, as the airport is officially on neutral territory and not recognised as part of Gibraltar by Spain. To make matters slightly more confusing, Spain regards the border in La Linea as "puesto de control policial" - or "police checkpoint", similar to those found in Ceuta or Melilla when departing for mainland Spain.

With respects to the controls within the airport, the idea is that there will be an additional part of the airport built on Spanish territory, which is where the Spanish control will be. I've been looking for more precise answers on this topic, and it appears that the idea is that the Spanish officers will be physically located in Spain, with gates placed in the Gibraltarian side of the terminal to prevent travellers from going towards baggage reclaim if they've been denied entry. Travellers themselves will stay physically in Gibraltar, and if there's a problem, the Gibraltarian authorities will be responsible for ensuring order.

At this point, if entry is refused, they can then return to the Gibraltarian police who will not detain them (even if they're wanted by Spain), but rather the traveller will have a choice of exercising their legal rights by consulting a lawyer and so on, or they will be able to return to the UK without entering Gibraltar. But this is very, very difficult from a political point of view, and it's by no means certain that Spain will agree to this system, especially under a likely future PP/Vox government. It also causes tremendous problems for Gibraltar, because Spain having a veto over British citizens entering Gibraltar is likely to cause a massive uproar.

The Government of Gibraltar admitted recently that the treaty is still not finalised, so all of this is still up in the air. The UK and EU will likely agree on it, but I wouldn't underestimate the level of uproar in Gibraltar if it turns out that Spain will be checking Gibraltarian passports/ID cards. It's going to be very difficult for the UK to agree to Spain having a veto over British citizens entering Gibraltar, and I wouldn't be shocked if part of the negotiations right now are along the lines of allowing Brits to enter Gibraltar only in the event of them being refused entry into Schengen. There's also a few other very contentious things in there, including a de facto sales tax of 17% and substantial increases in excise duties to match the EU minimums.