Schengen Visa Refusal, SIS Entry Ban & What Is Article 24?

The Schengen Information System (SIS) is the largest shared database used by 31 European countries for border security, public order and judicial cooperation. Member states add real-time alerts to share instant information about missing persons, wanted criminals, stolen vehicles and forged documents. These records are queried across thousands of terminals, from border checkpoints to police patrols, and the system returns a “match” within seconds.

1. Definition and History

SIS I (1995): Launched with the implementation of the Schengen Agreement

SIS II (April 9, 2013): Introduced photo and fingerprint support, larger character limits and extended object categories (vehicles, firearms, documents)

SIS Recast (unofficially SIS III, March 7, 2023): Introduced new biometric data (palm prints, DNA profiles for missing children), matching fingerprints of unknown suspects, return decisions and domestic violence alerts

1.1 SIS’s Role in the Schengen Area

SIS functions like an integrated border control system that provides a “green light” for passport checks. Border guards, police units and Europol access the same pool of data to maintain a unified security shield. It facilitates visa-free travel while quickly detecting forged documents, human trafficking and internationally wanted individuals. It is also designed for future integration with EU databases like ETIAS and EES.


2. How SIS Works

SIS has three layers: a Central Database (Strasbourg), a National Copy in each member state and front-end user terminals. The flow:

  1. A country enters an alert into its national system
  2. The national copy syncs to the Central System, which replicates it to all other countries
  3. When a border agent runs a check and there’s a match, further details are shared through the national SIRENE office

2.1 Data Categories and Alert Types

Main CategoryLegal BasisExample
Person wanted for arrestArt. 26 (Reg. 2018/1862)European Arrest Warrant
Missing or vulnerable personsArt. 32Missing child alert
Judicial summons/proceedingsArt. 34Witness summoned to testify
Entry ban (Refusal of Entry)Art. 24Schengen ban or visa refusal
Object alertsArt. 38Stolen car, passport or firearm
Discreet and Specific ChecksArt. 36Terrorism suspicion (discreet check)

2023 update: Added alerts for “unknown suspect fingerprints,” “return decisions” and “high-risk protective needs”

2.2 Role of National SIRENE Bureaus

Each country operates a 24/7 SIRENE office (“Supplementary Information Request at the National Entries”). Duties include:

  • Exchanging additional info after an alert match
  • Ensuring data accuracy in national copies
  • Coordinating arrest, extradition or deportation with other countries

For instance, if someone is flagged when entering Turkey, the local SIRENE office contacts the origin country’s SIRENE bureau.


3. Who Can Access SIS?

Only authorized public authorities. Unauthorized querying or copying of data is subject to severe penalties under EU and national laws.

3.1 Law Enforcement and Border Units

  • Police and Gendarmerie: Patrols, roadside checks and investigations
  • Border and Passport Control: Real-time checks at airports
  • Customs: Detecting stolen goods or forged documents
  • Europol and Frontex: Limited access during joint operations

They contact the SIRENE office when further documentation is needed after a “hit.”

3.2 Judicial and Immigration Authorities

  • Prosecutors and Courts: Check existing alerts when issuing a European Arrest Warrant
  • Immigration Offices and Visa Sections: Query SIS when processing Schengen visa, residence or return decisions
  • Correctional Institutions: Check if detainees are wanted abroad

Access is logged and audited based on legal authority and context.

4.  How to Check SIS Records

Under EU law, everyone has the right to access their personal data. This includes checking if your data is registered in SIS.

General steps:

  1. Identify the responsible authority (police, immigration or SIRENE office)
  2. Fill out a SIS access request form or write a free-form application
  3. Include a certified copy of your ID
  4. Submit by post or official email
  5. The authority verifies your ID and runs a search, usually replying within 30 days

4.1 KHow to Learn If You Have an SIS Record

StepDetails
1Download form → From police or SIRENE website
2Prepare documents → Passport copy, current address, wet signature
3Send → By post or registered email (varies by country)
4Wait → Response within 30–60 days
5Review → Result states either “No record” or the relevant article (e.g. Article 24 entry ban)

Some countries count the request as “automatically accepted” after 60 days if unanswered.

4.2 SIS Check Through an Attorney

  • In most countries, including Turkey, a lawyer can apply on your behalf.
  • The power of attorney must explicitly authorize “access to, correction and deletion of SIS data.”

5. How to Request Deletion or Correction of SIS Data

You can request correction (GDPR Art. 16) or erasure (GDPR Art. 17) if the data is incorrect or unlawful.

Steps:

  1. Prepare the request → SIS data rectification/erasure form or reasoned application
  2. Attach evidence → Visa refusal letter, court decision, passport
  3. Send to the competent state → Only the country that entered the alert can remove it via its SIRENE office
  4. Response time → Typically 30 days; up to 90 days for complex cases

5.1 Appeals and Required Documents

  • ID: Certified copy of passport or residence permit
  • Decision example: Visa refusal, deportation order or police report
  • Reason: Wrong identity, expunged criminal record, mistaken license plate
  • Evidence: Acquittal ruling, receipt, new passport

If complete, the SIRENE office processes the request within 60 days.


5.2 Legal Action

If denied, you can appeal in the administrative court of the country that entered the SIS record.
The typical deadline is 30 days from notification.
If the court suspends enforcement, the SIS alert may be temporarily deactivated.


6. How SIS Affects Visa Applications

Consulates must check SIS for every Schengen visa. An Article 24 alert (entry ban) leads to automatic refusal under Schengen Visa Code Article 32(1)(a)(vi).


6.1 SIS in Visa Refusal Reasons

The standard refusal form (Annex VI) has 11 boxes.
If refusal is due to SIS, it usually appears as Box 5: “Alert in SIS for refusal of entry” (Article 24 record).

BoxReasonSIS Link
1Forged or altered travel documentNo
2Travel purpose not justifiedNo
3Insufficient financial meansNo
4Exceeded 90 days in 180-day periodNo
5SIS entry ban alertDirect
6Threat to public order or securityOften Article 36
7No valid health insuranceNo
8Unreliable info/documentsIndirect
9No intent to leave before visa expiryNo
10No emergency reason for visa at borderNo
11Visa applicant voluntarily withdrewNo

6.2 What to Do After a Refusal

  • Administrative appeal: File with the consulate within 15–30 days
  • Correct SIS data: If refusal was due to an entry ban, first request SIS deletion
  • Reapply: After deletion, include confirmation in your new application
  • Litigation: If your appeal is denied, file in national court

By following these steps, you can complete your SIS inquiry, correct errors and reduce future visa risks.


7. SIS and Data Protection

SIS complies with the GDPR and EU Regulations 2018/1861-1862.
Everyone — whether an EU citizen or third-country national — has the right to access, correct or delete their personal data. These rights are free and must be answered within 30 days.


7.1 Data Retention Periods

Alert TypeReview Period*Example
Arrest or missing person5 yearsEuropean Arrest Warrant
Entry ban / Return decision5 yearsArticle 24 entry ban
Judicial summons / Unknown suspect3 yearsWitness call
Discreet check1 yearTerror suspicion
Object (vehicle, weapon, document)10 years (may vary)Stolen car

*Can be extended if the member state deems it “necessary and proportionate”

7.2 Rights and Applications

  • Access: Submit SIS access request form with ID
  • Rectification: Request correction with supporting proof
  • Erasure: Request deletion of unlawful or outdated alerts
  • Appeal: File lawsuit if unanswered or denied after 30 days

8. SIS 2025 Updates and Future Plans

The SIS “Recast” package became fully operational on March 7, 2023. In 2025, biometric and integration modules are expanding:

  • New alert category: Info alerts on third-country suspects (Europol recommendation)
  • Return decisions: Now shared automatically
  • Frontex and Europol: Granted full category access

8.1 Biometric Data Expansion

  • Palm prints and DNA profiles (only for missing children) added
  • Facial image quality standards published; facial recognition pending Commission report

8.2 Integration with Other EU Databases

VIS, Eurodac, EES, ETIAS and ECRIS-TCN will all connect through the “European Search Portal”
Operational timeline: 2024–2026; full migration target: October 2025 (EES launch)


9. SIS’s Role in Border Security

SIS enables passport-free travel within Schengen while providing instant alerts at external borders.
There are 20 million daily queries and 12.7 billion annual searches.

9.1 ANPR (Automatic Number Plate Recognition) and SIS

Member states feed live license plate data into SIS via ANPR cameras
In 2022, 8.35 billion automatic searches occurred, 65% with no human intervention

9.2 Terrorism and Organized Crime

Article 36 discreet checks let police covertly monitor a suspect’s movement and report to the requesting country
By the end of 2013, 41,097 people were listed under this category — a number that grows yearly


10. SIS FAQs

10.1 Common Issues and Fixes

ProblemCauseSolution
“No record found”Typo in dataRe-enter passport number and DOB
“Hit pending confirmation”Awaiting SIRENE responseRequest status from relevant office
“Access denied”Unauthorized userContact IT for proper permissions
“System offline”MaintenanceTry again later or use backup national copy

10.2 Pre-Travel Checklist

  1. Passport valid for 3+ months beyond end of trip?
  2. If previously refused, review refusal form reasons
  3. Submit SIS request before departure (response: ~30 days)
  4. If driving, ensure license plate is not flagged as stolen
  5. Note IMEI numbers of high-value electronics, keep receipts

11. Final Notes

To avoid Schengen visa refusal risks, applicants should review the visa refusal codes carefully, especially Box 5 (SIS entry ban via Article 24).
If SIS entry ban exists, the refusal is automatic. Therefore, complete the SIS inquiry steps.
If your SIS record is incorrect or unfair, request its deletion via the relevant SIRENE bureau — only they can finalize removal.
Once removed, reapplying with the official deletion confirmation reduces refusal risk.
Always include required documents (travel insurance, bank statement, accommodation proof), SIS report and prepare defense against likely refusal reasons (Boxes 1, 3 and 8).
Even though Article 36 alerts are less impactful than Article 24, a fresh SIS report is critical for assessing Schengen ban risk.
Also, including a GDPR-compliant data erasure request after refusal doubles your chances of success by presenting a transparent file free of Article 24 SIS entry bans.

12. Links

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32018R1862

https://eur-lex.europa.eu/eli/reg/2018/1861/oj/eng

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=legissum%3Ajl0028

https://ec.europa.eu/commission/presscorner/detail/en/ip_23_1505

https://schengen-it-systems.ec.europa.eu/print/view/pdf/glossary_terms/page_2?view_args%5B0%5D=w

https://gdpr-info.eu/art-16-gdpr

https://gdpr-info.eu/art-17-gdpr

https://www.eulisa.europa.eu/Publications/Reports/SIS%20II%20-%202020%20Statistics%20-%20report.pdf

https://www.eulisa.europa.eu/activities/large-scale-it-systems/sis

https://data.europa.eu/data/datasets/schengen-information-system-sis-statistics?locale=en

https://www.eulisa.europa.eu/news-and-events/news/sis-2020-statistics-report-now-available