June 17, 2025

Repatriation – Legal and Operational Landscape

The UK’s current landscape for sharing stolen vehicle information is in transition:

  • Pre-Brexit: Full access to EU systems gave UK law enforcement seamless integration.
  • Post-Brexit: Loss of SIS II and disruption of Prüm access led to reliance on INTERPOL and slower bilateral systems.
  • Going Forward: Reintegration with Prüm appears crucial for restoring rapid cross-border verification of stolen vehicle data, though full SIS II-style real-time alerts remain out of reach.

An overview of the present position with sources of further information, is as follows. This is intended to be an overview, at at early 2025 and should not be cited without first verifying the information conveyed. Best efforts have been undertyaken to ensure accuracy


House of Lords EU Committee Report (2021):

“Beyond Brexit: Policing, Law Enforcement and Security”

Chapter 3: Future UK-EU sharing of law enforcement and criminal justice data
Title II: DNA, fingerprint and vehicle registration data (Prüm)

This post-Brexit report critically examines the loss of real-time data sharing tools with the EU, particularly SIS II, and the replacement mechanisms introduced under the Trade and Cooperation Agreement (TCA). It discusses the impact of these changes on law enforcement, including vehicle crime.

Relevance to Stolen Vehicle Data:

  • Loss of SIS II Access:
    • SIS II was a central EU database that allowed real-time sharing of alerts, including for stolen vehicles.
    • UK police could automatically check number plates or VINs at borders and during investigations — this functionality ceased on 1 January 2021.
    • As the report notes, this resulted in slower and less integrated cooperation.
  • Replacement with INTERPOL:
    • UK now relies more heavily on INTERPOL’s SMV database, which is not real-time and lacks SIS II’s integration with national policing systems.
    • This adds operational delays, especially at borders.
  • TCA and Future Cooperation:
    • The TCA provides a framework for UK-EU law enforcement cooperation, but it does not replicate SIS II.
    • The agreement supports data exchange but with additional bureaucracy (e.g. via Europol/Interpol rather than direct alerts).

Impact:

The report strongly suggests the UK’s ability to rapidly identify and act on stolen vehicles across Europe has been weakened. While alternative channels exist, they are less efficient, making tracking stolen vehicles across borders more cumbersome and potentially less effective.


House of Lords EU Committee Report (2016):

“Brexit: Future UK-EU Security and Police Cooperation”

The United Kingdom’s participation in Prüm

This pre-Brexit report explores the likely consequences of the UK leaving the EU on justice and security cooperation. It focuses on practical tools like Europol, SIS II, and Prüm, and emphasizes the benefits of frictionless data exchange.

Relevance to Stolen Vehicle Data:

  • Emphasizes that access to EU law enforcement databases significantly enhances the UK’s ability to combat vehicle theft and cross-border crime.
  • SIS II and Prüm are called out as critical to effective policing.
  • The report warns that leaving the EU would mean losing automatic access to these databases and requiring new bilateral arrangements or slower mechanisms.

Impact:

The foresight of this report was accurate: the UK’s departure from SIS II and limitations with Prüm participation have made the process of sharing and accessing stolen vehicle information more fragmented.


The Prüm Framework

(Named after the 2005 Treaty of Prüm signed by several EU countries, now integrated into EU law)

The Prüm Decisions (Council Decisions 2008/615/JHA and 2008/616/JHA) establish a legal basis for automated exchange of DNA, fingerprints, and vehicle registration data (VRD) between EU member states to fight terrorism and cross-border crime.

Relevance to Stolen Vehicle Data:

  • Enables automated, near real-time exchange of vehicle registration data (VRD) held by national databases.
  • Supports cross-checking of number plates, vehicle ownership, and registration histories to help trace stolen vehicles.
  • Used in combination with data from other systems to flag suspicious patterns (e.g. multiple exports to high-risk countries).

UK’s Status:

  • The UK had opted into Prüm in 2016 (after an evaluation and Parliamentary approval).
  • Under Brexit, the UK lost Prüm participation but negotiated its re-entry under the TCA, subject to data adequacy and compliance checks.
  • As of the latest reports, the UK is expected to reconnect, but full participation is not yet operational.

Impact:

Once reconnected, Prüm would significantly improve the UK’s capacity to trace and confirm stolen vehicles through fast access to vehicle registration data held by EU countries – a critical capability given the UK’s role as both a source and destination for trafficked vehicles.


Legal and Operational Landscape

Framework/InstrumentWhat it DoesUK’s Current StatusImpact on Stolen Vehicle Info Sharing
SIS IIReal-time alerts on stolen vehicles & personsNo longer accessibleMajor loss of speed & efficiency in tracing vehicles
INTERPOL SMV DatabaseGlobal stolen vehicle registryFully accessibleStill functional, but not real-time, manual integration
Prüm SystemAutomatic exchange of vehicle registration data (VRD)Awaiting reimplementation under TCAOnce operational, will boost rapid access to EU VRD
TCA (Trade and Cooperation Agreement)Post-Brexit framework for law enforcement cooperationIn effect
(see pdf page # 689)
Legal basis for info sharing, but more complex and less seamless
Europol/SIENASecure intelligence sharing platformLimited accessUK can still share intelligence, but not direct database access

Remarks

  • The UK’s post-Brexit ability to share stolen vehicle information is still functional but reduced in scope and speed.
  • Tools like INTERPOL, bilateral agreements, and the TCA continue to facilitate sharing, but lack the real-time efficiency of SIS II or the automated querying power of Prüm.
  • UK authorities are working to restore some capabilities, especially through rejoining Prüm, which will significantly enhance their ability to trace stolen vehicles in Europe.
  • Legislative frameworks like the Data Protection Act 2018 and UK GDPR remain crucial in determining what data can be shared and how securely.

UK developments in Prüm participation timeline

DateEventDetails & Impact
2005Treaty of Prüm signedInitially signed by 7 EU states (not including the UK), aimed at enhancing cross-border cooperation in criminal matters.
2008Prüm integrated into EU lawVia Council Decisions 2008/615/JHA and 2008/616/JHA. Applies to all EU member states, enabling automated data sharing including vehicle registration.
2015Prüm Evaluation of the UK BeginsThe UK opts to assess potential benefits and readiness to participate in Prüm.
2016UK Parliament approves joining PrümFollowing a Home Office Business Case and parliamentary scrutiny, the UK opts in, citing high benefits in tackling cross-border crime.
2017–2020Implementation phaseUK prepares technical systems for Prüm VRD integration (e.g., connecting DVLA data). Progress slowed by Brexit negotiations.
Jan 2021Brexit ends UK participation in PrümUK officially leaves the EU, losing automatic access to all Prüm-based data exchange systems, including vehicle registration info.
Dec 2020TCA signedThe UK–EU Trade and Cooperation Agreement includes provisions for rejoining certain data-sharing mechanisms, including Prüm, pending adequacy and compliance checks.
2021–2024Evaluation for re-accessThe UK and EU work through compliance evaluations, including data protection adequacy and technical readiness.
2025 (projected)Expected reimplementationThe UK is expected to restore access to Prüm (initially for VRD, and possibly later for fingerprints/DNA) as part of law enforcement cooperation under the TCA.

Full Prüm reimplementation will restore near-instantaneous access to vehicle registration data across the EU, a key tool for tackling stolen vehicle trafficking and verifying registrations.

Visual comparison of SIS II vs. Prüm vs. INTERPOL

FeatureSIS IIPrüm (Vehicle Registration Data – VRD)INTERPOL SMV Database
PurposeReal-time alerts for persons & objects (e.g., stolen vehicles)Automated querying of vehicle registration data (who owns the car, where it was registered)Global registry of reported stolen vehicles
Geographic ScopeEU/Schengen AreaEU Member States and select associatesWorldwide (195 member countries)
UK Participation (Post-Brexit)Not accessibleRejoining (pending full implementation)Fully accessible
Data TypeAlerts, real-time watchlist info, stolen vehicle notificationsVehicle registration info (e.g., owner, registration number, VIN)Reported stolen vehicle data (basic metadata, VIN, make, model)
Speed of AccessReal-time, integrated with national police systemsNear real-time (automated search returns matches in minutes)Slower; requires manual query and cross-checking
Integration with UK SystemsPreviously high; now noneBeing re-establishedModerate; used by NCA, Border Force, and police
Primary Use CasesImmediate alerts at borders/police stopsVerification of registration data; tracing stolen vehiclesIdentifying and flagging internationally stolen vehicles
Limitations for UKNo access post-Brexit, major capability lossNot yet fully reconnected; pending legal and technical complianceNo real-time capability; not as comprehensive as EU systems
  • SIS II was the most effective for real-time tracking of stolen vehicles but is no longer available to the UK.
  • Prüm, once fully restored, will be the best alternative, especially for validating vehicle registration info.
  • INTERPOL remains a valuable global tool but lacks the speed and system integration of EU databases.

Summary of Benefits and Limitations for Each System

SystemStrengthsWeaknesses (for UK)
SIS IIReal-time alerts, border integration, comprehensive EU coverageCompletely inaccessible post-Brexit
PrümFast vehicle registration data lookups; automatedNot fully operational yet; rejoining process underway
INTERPOL SMVGlobal coverage, still accessibleManual process, slower response, lower data richness