The Case for a Visa Ban: Pathways to Denying Russian (Ex-)Combatants Entry to the EU

Up to 1.5 mn Russians have taken part in Russia's war of aggression against Ukraine since 2022. Three pathways to bar them from entering the EU are open today: national designations in the Schengen Information System (SIS), a visa ban in the 21st sanctions package, and a new standing category in the revised EU Visa Code.

The case for a ban rests on two distinct but overlapping threats: (1) covert, hybrid, and intelligence operations, and (2) criminality. From the front line in Ukraine, many Russian troops return home with a history of violence, weapons trafficking and looting, and with a sense of lawlessness and impunity. Returnees with combat experience are an ideal recruitment pool for sabotage and subversion by the Russian security services.

The initiative began in Estonia and has since been championed by Nordic-Baltic neighbours and endorsed by European states farther from Russia’s border, all of which share an understanding of the threat Russia poses. The ban has been adopted in principle in the sanctions package. However, it was narrowed along the north–south European divide and has been postponed until the measures needed to implement it are in place. Brussels still has to settle the evidentiary standard and the burden of proof so that the regime can survive judicial review. This may be less onerous and less resource-intensive than opponents suggest, because screening could rely on existing instruments:

• shared databases of proven (ex-)combatants, which would lead to automatic visa denial;
• a profile of a ‘typical Russian soldier in Ukraine’, which would trigger an extra security check;
• and a longer list of supporting documents, such as employment history and bank statements.

The SIS alerts filed by Estonia and Lithuania set a precedent that others may follow as a stopgap to close the visa-shopping loophole. The targeted ban could later be extended to personnel of other security services implicated in oppression in the occupied territories. Ukraine’s databases would help identify thousands of ex-combatants. A standing category in the Visa Code would change the task from compiling lists of names to defining criteria, and it would last longer than sanctions. In the end, the choice is between extra hours of consular work and the damage from an act of sabotage or terror that this work might prevent.