The Competitive Impacts of Digitising the Visa Application Process

In the last of three special blog posts on the visa application outsourcing industry, we consider whether greater digitisation of the visa process will further entrench incumbent competitive positions or open the industry to new players.

Since the visa application outsourcing industry launched in 2001, the visa application process has become increasingly digital. Biometrics, online applications, and e-visas are eliminating paper and physical artefacts across the visa application process, making life easier for visa applicants and offering new opportunities for companies operating in the visa application outsourcing space.

But not every digital transformation in visa processing benefits the incumbent players in the industry. The competitive positions of the largest players - VFS Global, TLScontact and BLS International - will come under increasing threat if the requirement for physical networks of hundreds of visa application centres worldwide diminishes due to digitisation, and the core competencies that national governments seek in a more digital visa application process deviate from the status quo.

So, how real is this competitive threat? 

And where will any competition come from? 

Let’s dive deeper into the factors that underpin the current competitive positions of the incumbent players and look at how the digitisation of the visa application process could disrupt them.

Visa Application Outsourcing Market

The visa application outsourcing industry is dominated by three players, who together account for around 75% of the global market by visa application volume. 

VFS Global is by far the largest of these three organisations, with approximately two-thirds of the worldwide market. The company is between 5-10 times larger than the second-placed player in the industry, depending on how one measures size. TLScontact and BLS International are the No.2 and No.3 companies in the market, whose positions at the top vary, again, depending on how one calculates size.

Other notable players include two of the prime contract holders for the US Government’s Global Support Services 2.0 contract - GDIT and CGI - as well as Capago, Greece Visa Center World, and CITS, the latter of which operates around 40% of China’s outsourced visa application network.

Newcomers to the industry are rare, and entry typically occurs through the acquisition of an incumbent player or through success in a procurement process that enables outside competition. Because the biggest barrier to entry into the visa application outsourcing industry is the way in which national governments procure visa outsourcing services.

Procurement Practices Limit Competition

Say you’re looking to buy something that’s a big deal for you. 

It may be expensive, and if it goes wrong, it’ll bring you professional shame and may even have broader negative impacts on your personal relationships. 

In this situation, how willing are you to buy a thing that, on the face of it, looks good, but is a prototype? 

Or will you plump for the thing that’s good enough and has been used millions of times by others for a decade or more?

That’s the decision-making process facing national governments when they procure visa application outsourcing services. The risk of going with something new - even if on paper it looks better than the rest - is far higher than going with a known quantity (the old ‘never-getting-fired-for-buying-IBM’ mantra from back in the day still applies!) This is why we typically see procurements for visa application outsourcing contracts significantly stacked in the incumbent players’ favour, hindering competition from outside.

To achieve this, national governments use a combination of administrative or ‘red line’ criteria in their procurement processes to limit the pool of competitors to companies with experience in visa application outsourcing. 

The requirements may be even stricter than merely ‘having experience’, such as having experience with a particular type of visa application outsourcing (e.g. Schengen visas), having operated a visa application centre in a specific country for a given number of years or having performed a minimum number of biometric enrolments for visa applications. 

The combinations are endless.

Here are a few recent examples from major visa application outsourcing procurements.

Switzerland: Cooperation with external service providers (CESP) in the visa process contract (2024)

Among 18 mandatory criteria requirements, whereby if the bidder failed to meet just one requirement, their bid would be eliminated, the Practical Experience element in requirement EC 14 required the following:

• “Experience in providing visa application outsourcing services over the last 7 years

• Presentation of five reference projects meeting the following criteria:

  • For each reference project a reference contact of the contracting authority must be indicated

  • At least two of the reference projects must be with Schengen Member States

  • Each mandate must be of a minimum duration of two years 

  • Service provision in at least three countries worldwide within the mandate

  • Service provision of the projects must be comparable with the present mandate and include the following service components:

    • Provision of information

    • Appointment management

    • Application processing

    • Visa fee processing

    • Electronic capture of alphanumeric application data

    • Electronic capture of fingerprints

    • Electronic capture of portrait photos (live or scanned)

    • Transmission of electronic application data (fingerprints and live portrait photo)

    • Transmission of paper files

    • Restitution of passports”

No organisation other than an experienced incumbent visa application outsourcer that has worked with Schengen Member States for many years could meet this criterion. Switzerland, therefore, excluded the possibility of any new player bidding and winning as a prime contractor.

Greece: Designation of Support Service Providers for Greek Consular Authorities or Consular Offices of Diplomatic Missions in the process of granting Entry Visas (type C and D) (2025/6)

Similar to Switzerland, in Greece’s most recent global visa application outsourcing procurement, Clause 7.5.3.4 i) required that for completed contracts, the bidder must submit:

“...at least one reference contract [...] involving support services for visa applications, concluded with a Contracting Authority of a Schengen Area state and related to the operation of Visa Application Centres.

This reference contract must demonstrate satisfactory and recent experience in designing, installing, operating, managing, and supporting services similar to those being tendered, including IT infrastructure and systems, and must meet the following criteria:

• Minimum duration of three (3) years, or shorter initial duration extended to at least three (3) years

• Involves collection of biometric data

• Covers processing of at least 15,000 visa applications per year

• Accompanied by a certificate of execution”

As with the above, only an incumbent player in the Schengen visa application outsourcing industry could meet these criteria as a prime contractor, as no outside organisation will have collected biometric data, processed more than 15,000 visa applications within a year and be able to provide a ‘certificate of execution’ from a Schengen government.

Canada: Migration Support Services For Immigration, Refugees And Citizenship Canada (2025/6)

It’s not just European countries that use this approach to whittling down potential bidders. Canada uses virtually the same approach, with Mandatory Requirement M1.1 in the request for proposal documents for its global visa application centre procurement, requiring that:

“The Offeror must demonstrate that it has provided Biometric Collection Services [...] under a contract to a single national government for a minimum of:

a)  1 year within the last 7 years as of the offer closing date; and

b) 10,000 individuals within any period of 1 year during the referenced contract.”

There’s a client reference requirement tied to the above that must be submitted as evidence. Unless your organisation has provided visa application services to a national government and meets the stated requirements, your bid will be evaluated as non-compliant and eliminated.

In an interview Souter Point conducted with a former procurement manager at Public Services and Procurement Canada (PSPC), the organisation responsible for evaluating major RFP responses to the Canadian Federal Government, our source informed us that they only want companies that have ‘been there and done that’ running their visa centre network. The contract is too expensive and politically sensitive to give to a newcomer; therefore, they structure the mandatory eligibility criteria to skew competition in favour of industry incumbent players. National governments take this approach on virtually all visa application outsourcing… but there are exceptions.

New Entrant Opportunities

Every now and then, a national government will procure in a way that enables a newcomer to enter the visa application outsourcing industry. And this is likely what we’ll see when the visa application process becomes even more digital.

There are three recent good examples of new companies successfully entering the visa application outsourcing industry at scale. Two of those come from the United Kingdom (and if you’d like to learn more, you should check out our article Is Remote Biometric Enrolment the Future of Visa Applications?), and the third from the USA.

Sopra Steria Enters the Market

When the UK Government outsourced the domestic visa application process for the first time in 2018, the £91m contract was awarded to Sopra Steria, a company with no prior experience operating visa application centres. As the UK Government wanted to foster innovation on the project, it opted for ‘outcomes-based’ evaluation criteria rather than the highly prescriptive mandatory criteria used by Switzerland, Greece, and Canada. The UK Government’s Green Book on the matter states:

“Proposals should initially be considered from the perspective of the service needed to deliver the required policy outcome and not from the perspective of a preconceived solution or asset creation. This guards against thinking too narrowly or being trapped by preconceptions into missing optimum solutions.”

This approach significantly opened the field to new competition, with many companies that had never operated in the visa application outsourcing space submitting proposals, such as G4S, Serco, and KBR. The Sopra Steria contract ran until 2024, when TLScontact replaced the company following the UK Government's re-procurement of visa application services.

Entrust Delivers the EU Settlement Scheme

Around the same time it awarded that contract to Sopra Steria, the UK Government also awarded a world-first remote identity verification programme for the EU Settlement Scheme to World Reach (now part of Entrust). Instead of tendering through an open process, the UK Government decided to use one of its G-Cloud procurement frameworks, soliciting bids only from pre-qualified bidders. As none of the three largest visa application outsourcing companies sat on this framework, they were excluded from bidding. 

It could be argued that the EU Settlement Scheme is not a ‘traditional’ visa application outsourcing contract, but given the industry’s direction of travel and the programme's success, it’s an exemplar project that other governments will be keen to replicate, with potentially the same lower barriers to entry for newcomers.

US Department of State Appoints Three Prime Contractors

Meanwhile, in the USA, there are three organisations on the Department of State’s Bureau of Consular Affairs Global Support Strategy 2.0 (GSS 2) framework, none of which operate visa application outsourcing contracts for other governments. 

CGI and GDIT both bought their places on the US Government’s framework contract through acquisitions. 

CGI landed on the original GSS framework contract with its acquisition of Stanley, while GDIT found its place on the framework with its acquisition of a company spun out of the split-up of CSC. 

The third company, Amentum Services, joined the new GSS 2.0 framework in 2020. 

While they may not provide visa application services for other national governments, what these three companies have in common is that they are large suppliers to the US Federal Government, with Federal certifications up the wazoo. 

There’s a reason VFS Global, TLScontact, and BLS International are not prime contractors on these deals: the eligibility criteria limit them to firms that already provide secure services to the US Federal government on a large scale. That said, VFS Global and BLS International act as subcontractors to these prime contractors, delivering in-country services while the prime contractors provide the technology and governance.

Therefore, when national government eligibility criteria can only be met by a large domestic firm, there is an opportunity for new entrants to bid for visa application outsourcing work on a more level playing field. But this type of procurement is rare and is typically seen only on contracts let by the USA, China, Japan, South Korea, and a handful of others.

The Impact of Digitisation on Competition

As the visa application process becomes more digital - and particularly if the conundrum around securely enrolling fingerprints remotely can be resolved - it’s possible that some national governments will begin to structure their RFPs in a way that enables more technology-focused firms to qualify. 

The two approaches the UK Government took - using an ‘outcomes-based’ RFP process and tapping existing digital framework contracts - could both open up competition. This would be desirable for national governments when visa application outsourcing contracts include more digital components, such as remote fingerprint enrolment, so that the likes of Entrust and similar firms with digital know-your-customer (KYC) experience can bring their expertise to the table. 

National governments may also consider splitting visa application outsourcing contracts by service delivery channel. It is entirely possible that a visa application outsourcing contract of the future could be divided between the providers of digital services (e.g. information provision online, remote identity verification and biometric enrolment, issuance of e-visas), physical services (e.g. physical in-country visa application centre to support non-digital application routes) and contact centre services (e.g. telephone, email, webchat and SMS services to support both of the above routes). 

Indeed, there is precedent for this. 

The UK has previously appointed separate physical visa application services providers and contact centre services providers, while the digitisation approach taken by the Schengen States has heavily involved Deloitte in the design and build of the new EU Visa Application Portal (EU VAP), effectively opening a large part of the digital services provision to an outside company.

In a world where the end-to-end visa application process - including fingerprint enrolment - can be performed from any location with an internet connection, the core competencies national governments will seek will not be ‘x number of years of experience providing a certain type of visa service in a given country’, but rather the proven ability to provide secure full lifecycle digital services. This means the incumbent visa application outsourcers will face stiffer competition from new entrants, rather than competing only among themselves in what are essentially restricted tendering processes.

Fighting Back

Just because the visa application outsourcing industry could face new-entrant threats from changes to government procurement processes and new digital technology requirements doesn’t mean the incumbent players will take this lying down. Indeed, throughout the industry’s history, the most successful firms have demonstrated their ability to harness digital supply chains to meet new requirements and then develop in-house expertise to deliver such services directly.

When biometric enrolment was first introduced, it was national governments that provided the hardware and software. 

Over the past decade, many major governments have moved to having the visa application outsourcer provide the biometric enrolment solution. This typically began with the visa application outsourcer procuring a turnkey solution from a specialist vendor, and has since evolved into VFS Global and TLScontact developing their own end-to-end biometric enrolment solutions. 

The specialist component parts of a biometric enrolment solution - the passport scanner, fingerprint scanner and quality control software - still come from a small number of external vendors; however, the visa application outsourcer has greater control over which cameras to use, the system user interface design, encryption protocols and the form factor of the biometric enrolment solution. 

As the digitisation of the visa application process and the broader adoption of remote biometric technologies advance, we expect the technology strategies of incumbent visa application outsourcing providers to follow a similar path. Initially, they’ll likely buy turnkey solutions from specialist firms, then develop their own in-house solutions using the same components. After enjoying a dominant position in the industry for almost three decades, these companies will not give up without a fight.

Not Taking It Lying Down

Digitising the visa application process will undoubtedly present opportunities for new entrants to enter the industry. 

Contracts with higher levels of digitisation will attract more traditional technology-based service providers, as the emphasis on a physical network of visa application centres worldwide will diminish. 

However, this increased competition will depend almost entirely on how national governments procure outsourced visa services in the future. If they continue to require experience providing outsourced visa services to national governments or collecting biometric data from large numbers of visa applicants, competition will remain among the existing players.

And as the largest incumbent players in the visa application outsourcing industry have proven adept at developing their own technology to support physical services, there is little reason to expect they will not continue to do so and remain at the forefront of the industry.

Furthermore, when national governments value experience and want an external service provider who has ‘been there and done that’, it is clear that, when re-procuring visa application outsourcing services, these will remain essential quality criteria. The risk to incumbent players, therefore, rests entirely on how national governments procure the new digital components of the visa application process… and on whether they split the scope of work between the digital and the physical.

Souter Point provides consulting services to governments and private-sector businesses in the visa and immigration space, including strategic advice, research, and sales support, such as bid management and new market-entry strategy development. We also work with management consultancies, institutional investors and other interested parties to help them gain a clear understanding of how the global visas and immigration industry operates. If you’d like to learn more about what’s happening in the visa and immigration space and where it might lead, please send us an email at gri@souterpoint.com, and we can schedule a call to discuss your needs.

.