the EU’s listing of recognized fantasy and camouflage passports – Cyber Tech
Jacques
BELLEZIT (College of Strasbourg)
Picture
credit score: Syced, through
Wikimedia
Commons
Because the Grzelczyk judgment, the European Court docket of
Justice has held that « Union citizenship is destined to be the
basic standing of nationals of the Member States », prioritizing
the liberty of motion utilized by EU residents over different EU basic freedoms.
This
prominence has pushed the Court docket to sentence the Maltese investor citizenship
scheme which “quantities to the commercialisation of the granting of the standing
of nationwide of a Member State and, by extension, Union citizenship, which is
incompatible with the conception of that basic standing that stems from the
Treaties” (level 100 of the ECJ Grand Chamber “Fee v Malta” judgment of 29 April 2025).
At the side of the precept of honest cooperation outlined in TEU
Article 4, one can higher perceive the significance of a superb understanding of
EU member States’ passports by nationwide immigration and customs authorities.
To implement this understanding, a number of authorized instruments are established inside the
EU authorized system. Amongst them Determination No 1105/2011/EU of the European Parliament and of
the Council of 25 October 2011 establishes a “listing of journey
paperwork which entitle the holder to cross the exterior borders and which can
be endorsed with a visa and on establishing a mechanism for establishing this listing”.
The stated EU listing of journey paperwork is split into three elements (Article 1
of the Determination 1105/2011/EU), that are:
Half
I : Journey paperwork issued by third international locations and territorial entities.
Half II: Journey paperwork issued by Member States.
Half
III: Journey paperwork issued by worldwide organisations.
Nonetheless, this listing has a “doppelgänger,” a “mischievous” twin.
Certainly, below article 6 of the Determination N°1105/2011/EU “The Fee shall
additionally draw up and replace a non-exhaustive listing of recognized fantasy and camouflage
passports on the premise of knowledge obtained from the Member States.” (hereafter
« the EU listing of recognized fantasy and camouflage passports » or
« the Listing »).
This Listing, obtainable on the web site of the
Public Register of Genuine id and journey Paperwork On-line (PRADO, being itself a bit of the Council’s
web site), which is the subject of the current research, was lastly up to date on
31.08.2025 and shows 3 classes of “passports” on which
Member States’ authorities are forbidden to endorse an EU-Schengen visa :
·
Fantasy
passports (‘Passports’ issued by minorities, sects and inhabitants teams and
id paperwork, and many others. issued by personal organisations and people.
·
Camouflage
passports (Passports of former states now not in existence).
·
Paperwork
of territories which aren’t internationally recognised.
If
the problem of “former states non longer in existence” is a recognized object of worldwide
legislation (cf. The Vienna Conference on Succession of States in Respect of Treaties –
Vienna, 23 August 1978 United Nations, Treaty Collection , vol. 1946, p. 3. C.N.354.2008.TREATIES-1 of 6 Could 2008) as nicely
because the conundrum of “territories which aren’t internationally recognised”
(cf. as an illustration the Western Sahara, dealt by the Luxembourg Court docket within the
“Entrance Polisario” judgments of October 4th 2024 (C‑778/21 P and C‑798/21 P ; C‑779/21 P and C‑799/21 P, C-399/22), the problem of “fantasy passports”
is extra nebulous.
If States (and, to a lesser extent, worldwide organizations) have the
privilege to situation passports on their behalf, the EU Member States have,
moreover, the duty to respect
EU legislation whereas withdrawing their nationality, particularly relating to the influence on
EU citizenship and the entry to the Schengen Space (cf. CJEU Judgment of the
Court docket (Grand Chamber) of two March 2010. Janko Rottman v Freistaat Bayern
Case C-135/08
p.54-55).
Below
these circumstances, it’s comprehensible that third actors might be tempted to
apply for an EU-Schengen visa to acquire open entry to the Schengen space in any respect
prices, though the emission of such fantasy and camouflage passports.
Nonetheless, using “State Emblems, Official Hallmarks, and Emblems of
Intergovernmental Organizations” as logos is by itself prohibited below IP
legislation (cf. Article 6ter of the Paris Conference for the Safety of Industrial
Property of March 20, 1883 and, in EU legislation, Article 7 h) of the Regulation (EU) 2017/1001 of the European Parliament and of
the Council of 14 June 2017 on the European Union commerce mark ), and
such use may result in prison prosecution not solely below IP legislation, however below
different safety fields.
For example, the “Principality of Sealand” (occurring on the Listing and amongst
essentially the most well-known micronations) is a small platform of 0.0004 km² inside
the British territorial waters. The Principality’s “authorities” participated
within the 2000s cash laundering scandal about “Sealand passports” (cf. Gooch,
Adela (12 April 2000). “Police swoop on Sealand crime ring”. The Guardian. ISSN 0261-3077.;
Boggan, Steve (23 September 1997). “Cash Laundering: World
fraudsters use sea fortress as passport to”. The Unbiased.). In the present day, it provides a “E-Citzenship” program which permit such E-Citizen
the use of a “Free & Safe VPN
entry”, in addition to the “safety from Sealand authorities”, or a number of
reductions on merchandising associated to Sealand. James Grimmelmann theorized that
the platform was additionally a possible information haven by means of its firm
HavenCo Restricted. (cf. Grimmelmann, James (27 March 2012). “Loss of life of a knowledge haven:
cypherpunks, WikiLeaks, and the world’s smallest nation”. Ars Technica.)
Below this consideration, one can simply perceive using the EU Listing on
safety, struggle in opposition to money-laundering and different offences.
After a fast overview of the primary two classes of passports and paperwork
(I) we are going to focus particularly on the fantasy passports as they intention, on numerous
scales of Genuity, imitate official, common State-issued paperwork (II). Such
fantasy passports are an attention-grabbing funhouse mirror, permitting reflections on
what a State is as we speak, below the prism of a European Union which is itself not
a sovereign State (III).
I)
Camouflage
passports and non-recognized territories below the EU Listing
A 1989 Soviet
Passport, image of an precise camouflage passport.
(File:Soviet Passport Cowl HiRes.jpg. (2025, June 1). Wikimedia Commons.
Retrieved December 9, 2025, from https://commons.wikimedia.org/w/index.php?title=File:Soviet_Passport_Cover_HiRes.jpg&oldid=1038965939.)
The 27 “Former
states now not in existence,” are acquainted to any historical past and/or
worldwide relations fanatic: One can take into consideration the Federal Republic of
Yugoslavia”- whose succession has been handled by the Badinter Fee
(Radan, P. (1997). The Badinter arbitration fee and the partition of
Yugoslavia. Nationalities Papers, 25(3), 537-557.) or
the USSR, divided following the 1990 Minsk Declaration (cf. Hamant Hélène. La succession
d’États de l’URSS en matière militaire. In: Annuaire français de droit
worldwide, quantity 50, 2004. pp. 213-230.)
Nonetheless, past these two former main impartial States, the listing primarily mentions former European colonies and assimilated territories, together with their present names and sovereignty.
We are able to point out “ Rhodesia (now Zimbabwe)”, “Ceylon (now Sri Lanka)” or Netherlands East Indies (now Indonesia) as
nicely as “Bophuthatswana” and “Transkei”,
former South African Bantustans which have
been theoretically impartial in the course of the apartheid period, however at the moment are a part of
the South African territory (Hattingh, P. S. (1977).
Bophuthatswana at a Look. Africa Perception, 7(2),
213-219; Drummond, J. (1991). Reincorporating
the Bantustans into South Africa: the query of Bophuthatswana. Geography, 76(4),
369-373.)
Inside territories
which aren’t internationally recognised, one can discover solely 4 territories
that are, particularly, “Turkish Republic of Northern Cyprus”, “ Saharwei, Arab
Democratic Republic (personal title for ‘Western Sahara’)”, “ Non permanent Authorities of
Serbia at Kosovo”, and “Republic of Somaliland”.
About “Turkish Republic of Northern Cyprus”, the Listing qualifies this territory
as “Unlawful below UN Safety Council Resolutions 541/83
and 550/84”, however it’s silent in regards to the different
territories: for “Non permanent Authorities of Serbia at Kosovo”, one can relate it
to the truth that the scenario of Kosovo nonetheless sparks controversies: for
occasion the Mandate of the European Union Particular
Consultant for Kosovo warns that the “Kosovo” denomination is “ with out
prejudice to positions on standing, and is consistent with UNSCR 1244/1999 and the
ICJ Opinion on the Kosovo declaration of independence”.
The scenario of Western Sahara could evolve following the aforementioned “Entrance
Polisario” judgements, however we doubt the “Saharwei, Arab Democratic Republic”
will quickly be struck off the Listing.
About
Somaliland, the instability of this separatist area of Sudan (being a sizzling
level of pluri-ethnic tensions and Jihadism) appears to ban this “Republic”
from succeeding in gaining worldwide recognition (cf. Matt Bryden “Somalia
at Threat of Turning into a Jihadist State” Africa
Safety Transient No. 45
Africa Middle for Strategic Research, November 17, 2025).
Past these States (extinct or claimed), the Listing mentions fantasy passports
and paperwork issued “by minorities, sects and inhabitants teams [and] by
personal organisations and people”.(hereafter “third actors”).
II) Fantasy passports
as a step towards prison offence or worldwide recognition.
The Listing gathers, in a non-exhaustive method, 152 sources of fantasy passports and
paperwork that we will subdivide into 4 classes of passports and paperwork,
that are non-mutually unique.
–
Pseudo-diplomatic
paperwork.
–
Pseudo-religious
paperwork.
–
Nationalists’
paperwork.
–
Cargo-cultist
paperwork.
If
counterfeit paperwork and id paperwork forgery generally is a software for numerous
offences (reminiscent of terrorism cf. Molnár, Á. (2019). Journey Paperwork in use by
Terrorists. Inner Safety, 11, 133-145; Rudner, M.
(2008). Misuse of passports: id fraud, the propensity to journey, and
worldwide terrorism. Research in battle & terrorism, 31(2),
95-110.), it may also be a strategy to acquire recognition from micro-nations (cf.
Hobbs H, Williams G. Micronations and the Seek for Sovereignty.
Cambridge College Press; 2022.), spiritual or Indigenous minorities on an
worldwide plan.
Pseudo – diplomatic paperwork
About
“Pseudo-diplomatic paperwork”, the Listing mentions teams of organisations that
counterfeit or corrupt the names of real worldwide organisations in a
parasitic method, aiming to “mislead the general public” (in an identical strategy to instances aimed
by article 58 c) of the Regulation (EU) 2017/1001)
We are able to point out so-called organizations such because the ‘Baltic Commerce Mission’, ‘Diplomatic passport of ‘Comité Worldwide
pour la Safety des Droits de Hommes’ (CIPDH) ; ‘EU Senator Cross’, ‘IIMSAM’
(Inter-Governmental Observer to the United nations Financial and Social Council)
– Diplomatic Laissez passer (DE)” or ‘Intergovernmental Establishment for the Use
of Micro-Algae Spirulina In opposition to Malnutrition’. Some organisations might be
complicated, reminiscent of “Arab Worldwide Organisation” (cf. the true world League of Arab States) or the “Organisation of African
Unity” (disbanded in 2002 and changed by the African
Union.
Nonetheless, claiming to belong to such an “worldwide group” doesn’t
grant as such privileges that are much like these granted to real
worldwide relations: as an illustration, in case ECJ (Full Court docket) 30th
September 2021 (C-130/19) Pinxten, it’s recalled that “[…]
excise items are exempt from fee thereof the place they’re supposed for use
within the context of diplomatic or consular relations or by worldwide
organisations recognised as such by the general public authorities of the host Member
State, and by members of such organisations, inside the limits and below the
situations laid down by the worldwide conventions establishing such
organisations or by headquarters agreements.”
Certainly, as said by
Thomas MENRAH “The necessity for a Headquarters Settlement arises from the actual fact
that there are particular elements of the relations between a corporation and
its host State that won’t simply be resolved by reference to common
rules of worldwide legislation and even the provisions of common conventions
on privileges and immunities.” (Mensah, T. A. (2012). “Headquarters
Agreements and the Regulation of Worldwide Organizations”. In Coexistence,
Cooperation and Solidarity. Leiden, The Netherlands: Brill | Niehoff. https://doi.org/10.1163/9789004214828_071)
However
because the Listing’s “worldwide organizations” don’t exist, the privileges,
allegedly “laid down by […] worldwide conventions establishing such
organisations or by headquarters agreements” of their self-claimed brokers
are additionally non-existent.
Pseudo-religious organizations
On pseudo-religious organizations, we will quote the “‘Hare Krishna Sect’
(Krishna-Consciousness) labelled as a cult (cf. Melton, J. Gordon. “Hare
Krishna”. Encyclopaedia Britannica, 27 Oct. 2025,
Accessed 24 November 2025
).
The ‘Sovereign Navy Order of St. John of Jerusalem’ is a mixing of the
(catholic) Sovereign Navy order of Malta (with a sui generis statute
in worldwide legislation, cf. UN Normal Meeting Decision A/RES/48/265 of August 30 1994)
and of the Order of St. John of Jerusalem, which don’t profit from such
standing. One may point out the “ ‘Knights of Malta’ (‘UN diplomatic
passport’) ‘Cosmopolitan Passport.’
Lastly, we will take into consideration marginal teams relating themselves to Orthodox
Japanese spiritual organisations such because the “Ecumenial World Patriarchate” the “‘Byzantine
Empire’ (‘passport’ issued by the ‘Holy Roman Empire of the East’)” or the
“‘Patriarchate of Antiochia” that hope to profit in a parasitic method of
privileges granted to Vatican State, or the Mount Athos communities. This
latter query have been deal by the 1979 “Joint Declaration regarding
Mount Athos” (cf.
Papastathis, C.-Ok. (2004). Le statut du Mont Athos. L’Année canonique, Tome
XLVI(1), 141-158. https://doi.org/10.3917/cano.046.0145.)
Nationalist paperwork
Inside the level of “Nationalists paperwork,” we will put collectively the case of
micronations (cf. Hobbs H, Williams G. supra) such because the “Principality
of Sealand” or the ‘Hutt River Principality”, in addition to paperwork issued,
allegedly, by Native populations, whether or not they’re from Northern America (e.g.
‘Empire Washitaw de Dugdahmoundyah’ , ‘Hadenosaunee’, ‘HOPI Indians’) or from different places (
‘Hawaiian Kingdom’ ; ‘Republic of Chechen’ or the ‘Republic Malaku Selatan’
(South Moluccas)”).
The reference to
such Native populations goals to make use of the problem of such populations’ decline or
even demise. It could be consistent with a authentic want to dwell in accordance
with their conventional life-style, and even, to talk with worldwide legislation
language, to make use of their rights to self-determination to exclude any jurisdiction,
besides their very own.
The exclusion of standard States’ jurisdiction can also be a characteristic of what’s
referred to as “sovereign citizen actions”
which use pseudo-legal rhetoric and details: it’s the case with, for
occasion, the “‘Baltic States’ (‘passports’ issued by the federal government in
exile)”, or for the “‘Notverwaltung
Deutscher Osten’ (Emergency Administration of the German East) – Diplomatic passport”
in addition to “Vereinigte Länder des Deutschen Ostens im Deutschen Reich’ (United
Nations of the German East within the German Empire)”.
The latter two references to the “German East” might be associated to German
sovereign citizen actions (a.okay.a “Reichbürger” or “Residents of the
Reich”) which
refuse the legality of the present German Federal Republic (GRF): within the eyes
of those actions, neither the German Empire, nor the German Democratic
Republic have legally disappeared following the 2 World Wars. Subsequently, the
GRF being illegitimate, its authorities might be overthrown.
A “Reichbürger passport” amongst different German sovereign citizen actions objects.
(Supply
: https://www.verfassungsschutz.de/EN/subjects/reichsbuerger-and-selbstverwalter/reichsbuerger-and-selbstverwalter_node.html)
Nonetheless, because the Worldwide Court docket of Justice said in its 1995 “East-Timor” (Portugal v Australia) judgement
(§29) “The precept of self-determination of peoples has been acknowledged by
the United Nations Constitution and within the jurisprudence of the Court docket […] it’s one
of the important rules of latest worldwide legislation. Nonetheless, the
Court docket considers that the erga omnes character of a norm and the rule of consent
to jurisdiction are two various things”.
What’s true earlier than the Hague Court docket ground continues to be true earlier than any authority:
invoking the erga omnes character of a norm doesn’t deprive “magically”
and per se customs and immigration authorities of their jurisdiction
over a person, and that’s very true if the stated particular person carries a
fantasy doc which has no recognition anyplace.
The
magic mind-set is a attribute of the final class of paperwork:
the Cargo-cultist, which is an attention-grabbing funmirror of what a State is.
III) Fantasy passports : an attention-grabbing funmirror of the twenty first Century State
In accordance
to Claudine CASSAR, such cults stems from contacts between Melanesian and
Western populations because the 19th Century : as she writes “Members of the cult imagine
that the Western materials items they want aren’t merely produced by human
labour, however somewhat come from supernatural sources. The rituals and practices
that Cargo Cults make use of usually contain imitating the behaviour of Westerners,
reminiscent of constructing runways, utilizing radios to speak with the spirits, or
carrying clothes resembling army uniforms.” to profit from Western
items.
From
the plentiful literature on the subject (cf. inter alia Lindstrom, Lamont.
(2018) 2023. “Cargo cults.” In The Open Encyclopedia of Anthropology,
edited by Felix Stein. Facsimile of the primary version in The Cambridge
Encyclopedia of Anthropology. On-line: http://doi.org/10.29164/18cargo), these “imitations” are crafted
by cultists with out the data of the logistic chain and/or the political arcane,
permitting Westerners to convey their materials items to distant Melanesian islands (cf. Billings,
D. Ok. (2002). Cargo cult as theater: Political efficiency within the
Pacific. Lexington Books.)
In
the case of fantasy passports, a few of their bearers could naively suppose that
exhibiting their “paperwork” issued by State-like entities (e.g. ‘Pas Valasheko
Kralovsztvia / Passport of the Wallachian kingdom’ ; ‘United Nations of America, State of Delaware’
; ‘Free and Unbiased State of Vera
Cruz’ ) or pseudo-international organisations (e.g.“ ‘Worldwide Parliament
for Security and Peace’; ‘Kingdom of Dutch World Residents’ ) could divulge heart’s contents to them
worldwide borders and acquire them the respect and deference of native
authorities.
Nonetheless, it’s loud and in clear in worldwide legislation that “Notification to
the receiving State of appointments, arrivals and departures” (Article 24
of the Vienna Conference on consular relationships) of diplomatic employees have to be
performed, which is troublesome if the sending State or entity doesn’t exist.
This
feeling might be strengthened within the thoughts of “cargo-cultists” by the continual
thrive of the Web and IA applied sciences,
which see the start of so-called “numeric nations” or “e-nations” dwelling
away from a situated bodily territory (e.g. the “First
House Nation” of ASGARDIA);
Alshamsi, H., Balleste, R., & Hanlon, M. L. (2018). House station Asgardia
2117: From theoretical science to a brand new nation in outer house. Santa
Clara J. Int’l L., 16, 37.; Putra, M. R. (2023). Juridical
Evaluation of the Kingdom of Asgardia House from the Phrases of a State In accordance
to Worldwide Regulation. Siber Worldwide Journal of Superior Regulation
(SIJAL), 1(1), 9-15.).
The “Principality of Sealand,” whereas providing an E-Citizenship program, forbids
“any proper of abode or bodily residency inside the Principality of Sealand
(…) primarily confers digital rights and privileges, as outlined within the Sealand
E-Citizenship program particulars”. On this level, one has to note that the Phrases & Circumstances of this program are “ ruled
by and construed in accordance with the Regulation of England and Wales and Sealand”
(sic). Nonetheless, if there’s an unique electio fori clause
granting “unique jurisdiction of the Courts of England and Wales. 95A
Prince Ave, Sounthen-on-Sea, Essex, SS2 6RL.”, one may discover that, in
case of an arbitration continuing, this latter might be carried out “in
accordance with the foundations of the Worldwide Chamber of Commerce (ICC). The
arbitration will happen in Sealand, and the language of the arbitration
might be English.” An arbitration process on a former army platform would
be remarkable, to any sense of the phrases (!).
Furthermore,
paragraph 363 of the “Obligations of States in respect of the local weather change”
ICJ’s advisory opinion of July 23rd 2025 may additionally nourish cultic
fringe views on touring paperwork: because the World Court docket said that “as soon as a
State is established, the disappearance of one in all its constituent parts
wouldn’t essentially entail the lack of its statehood”, we’d count on a
rise of recognized fantasy and camouflage passports going together with a potential rise
of micronations or numeric nations.
However
what’s the distinction between genuine state-issued paperwork and these recognized
fantasy and camouflage passports?
In
our view, it’s the recognition of a topic of worldwide legislation: we will say
that the Listing is a typical listing of unrecognized and principally unrecognizable
international locations, those who don’t have the “crucial mass” or fulfil the situations
to say/acquire recognition.
In EU asylum legislation, one can discover a related momentum with the “Procedures”
Directive 2013/32/EU of the European
Parliament and of the Council of 26 June 2013. Article 38 of this Directive states the idea of “secure third international locations”
permitting, inter alia, using accelerated procedures. If
the safe-third nation idea is outlined by the factors laid on this article,
the EU listing of recognized fantasy and camouflage passports is predicated on one
truth: notoriety.
Issuing
« authorities » of such paperwork are « recognized » publicly to
act fraudulently and/or with out the required sovereignty to emit legitimate journey
paperwork. It could most likely quantity to self-evidence or widespread sense that
paperwork “issued by minorities, sects
and inhabitants teams “ or “ issued by
personal organisations and people” are and must be , per se,
invalid.
So we will surprise why EU Member States do to often share info on the
subject? as a result of lack of CJEU case-law on the “fantasy and camouflage”
paperwork, there isn’t any autonomous notion of such paperwork (comp. with the
notion of “traveller” below Directive (EU) 2015/2302, CJEU (W)onderweg, C‑445/24,
13 November 2025 §34).
One
can discover a lifeless finish as the popularity of different States is an acta de jus
imperii, interlinked with the Widespread International and Safety Coverage, extremely
strategic and (practically) proof against judicial assessment by the European Court docket of Justice
(Article 24 TEU).
However, if third States
have entry to EU Courts (cf.Kassoti* and Carrozzini**A Curia Mundi? The CJEU’s Judgment
in Case C‑872/19 P Venezuela v Council), can
these non-state actors focus on their inscription on the Listing ?
The Luxembourg Court docket case legislation has a number of instances of minorities, sects (cf. for
the member of a “Bhagwan neighborhood” CJEU Judgment of the Court docket (Sixth Chamber)
of 5 October 1988 Udo Steymann v Staatssecretaris van Justitie. 196/87) and
inhabitants teams (cf. CJEU (Grand Chamber), 3 October 2013, Inuit Tapiriit
Kanatami and Others v European Parliament and Council of the European Union)
which can seize the EU Court docket in the event that they fulfil the related situations, or are the topic of a reference for a preliminary ruling from a nationwide courtroom.
If is admitted that third States and EU Members States can, inter alia,
seize the European Court docket of justice below situations of TFEU Part 5; we
may count on, someday, the query of those fantasy passports to land earlier than
the Luxembourg Court docket’s ground (immediately or by the way in which of a preliminary ruling).
Conclusion
If the EU Listing is enshrined in a bigger “ listing of journey paperwork
which entitle the holder to cross the exterior borders and which can be
endorsed with a visa “ established by Determination No 1105/2011/EU of
the European Parliament and of the Council of 25 October 2011, it’s
nonetheless wealthy of teachings on the disaster of the Westphalian State, seen
by means of the lens worldwide and EU legislation.
Different
actors, roughly organized, intention to
compete with States for the obtention of worldwide recognition, embodied and
symbolized by these passports and paperwork talked about within the Listing.
These
actors could also be voluntarily or not pushed by mischievous or naïve emotions, however
their creativeness and the flexibility of instruments at their disposal, in addition to
their pseudo-State discourse, must warn public authorities and the overall
public of dangers linked to those practices.
The play on phrases and the confusion round diplomatic and authorized vocabulary could
deceive the general public (and, to a lesser extent, public authorities) and lay a
beneficial floor for additional, advanced offences, in an instance of real-life, social engineering approach.
Past safety and cooperation points, one should point out that some passports
are purposely issued as souvenirs or marks of regional and or inventive
identities with none will to hurt anybody. For example, the “Passeport
Alsacien”
(Alsatian passport) is a fantasy passport aimed for leisure and the
promotion of this Japanese France’s particular id, with none grounds to
declare worldwide recognition of any sort.
Certainly, Alsace’s foremost metropolis, Strasbourg, is thought to be the siege of the
European Parliament in addition to internet hosting the Council of Europe’s establishments. As
such, this sole truth may exclude the latter passport from being a part of the
EU Listing.
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