In 2024, when Thai Prime Minister Srettha Thavisin proposed a joint visa for six ASEAN countries, many media outlets described it as a "Schengen-style visa." The comparison sounded reasonable because both are associated with facilitating cross-border travel.
However, equating AFAVE (the ASEAN Framework Agreement on Visa Exemption) with the Schengen system is like equating a bilateral trade agreement with a single market. The difference is not merely one of scale; more importantly, their legal architectures were never designed to serve the same purpose.
In 2024, tourism and travel contributed 9.7% of ASEAN's GDP, equivalent to US$379 billion, and supported 42 million jobs, according to the ASEAN Tourism Outlook 2025. The region is projected to receive more than 200 million international tourist arrivals over the next five years.
With figures of that magnitude, the question of a single visa is not merely a policy discussion; there are concrete economic interests behind it. However, the data also show that ASEAN and Europe operate on two fundamentally different foundations.
One Framework, Dozens of Agreements
The ASEAN Framework Agreement on Visa Exemption (AFAVE) was signed on July 25, 2006, in Kuala Lumpur. The agreement did not create a single visa.
Instead, it established a framework through which member states could negotiate separate bilateral protocols, with visa-free stays of up to 14 days per visit.
Technically, AFAVE has not yet entered into full force because not all member states have completed ratification. In practice, what operates on the ground is the bilateral implementation between individual member states, with varying durations of visa-free access.
The Schengen system, by contrast, functions very differently. A single visa is valid across 29 countries simultaneously, allowing stays of up to 90 days within a 180-day period.
In 2024, the consular authorities of Schengen countries received more than 11.7 million short-stay visa applications, and more than half of those visas permitted multiple entries throughout the entire Schengen area, according to data from the European Commission. Every day, approximately 3.5 million people cross internal Schengen borders without border checks.
What makes this possible are three elements that ASEAN does not possess: a common visa policy applicable across all member states, a shared security database known as the Schengen Information System (SIS), and a collectively managed external border.
In ASEAN, none of these three elements exists. Cross-border movement remains entirely subject to the domestic immigration laws of each member state.
The Difference Lies in the Foundations
The absence of a unified system in ASEAN is not because the region has yet to "reach" Europe's level of integration. It is a direct consequence of the way ASEAN was built.
The European Union has supranational institutions, such as the European Commission, the European Parliament, and the Court of Justice of the European Union, to which member states have delegated part of their legal authority to make binding decisions.
ASEAN, however, has no comparable structure. Decision-making within ASEAN depends entirely on the political will and commitments of its individual member states.
The principle of non-interference, which has been a cornerstone of ASEAN since 1967, means that no member state can be compelled to align its immigration policies with those of another.
The harmonization of security mechanisms, the sharing of biometric data, and joint border management are not merely technical challenges. They directly touch on questions of sovereignty that member states have traditionally guarded closely.
Connected, But Not Unified
Those foundations continue to shape conditions on the ground today. For tourists wishing to travel around Southeast Asia, the experience is relatively convenient in practice, but not because a unified system exists.
Most ASEAN citizens can enter fellow member states without a visa, although the permitted duration varies depending on the bilateral agreements between each pair of countries. Travelers from outside ASEAN can generally apply for e-visas or visas on arrival separately for each country.
What does not exist is a single document valid across multiple countries. As a result, every border still operates under its own rules.
Looking ahead, the ASEAN Tourism Sectoral Plan 2026–2030, launched in Cebu in January 2026, identifies "accessible and seamless travel" as one of the region's five key priorities.
This includes improving air and maritime connectivity, as well as simplifying cross-border procedures, but it still falls short of a single-visa system. The focus is instead on practical integration: ASEAN is promoted as a single destination, while each country retains full control over its own points of entry.
The gap between "feeling like a single region" and "being a single region in legal terms" remains the defining distance between ASEAN and Schengen.
