You have surely heard about your obligations to submit your passenger data to EU states you are flying from/to… APIS Advance Passenger Information and/or PNR Passenger Name Record. But, it is still not crystal clear for you… what should you do? What is requested and by which state? This article aims to provide answers to those questions.
What do the EU regulations say about API or PNR (PNRGOV)?
Under the PNR Directive, all air carriers must transmit passenger data to the authorities of EU Member States before the departure of any international flight (inbound and outbound). These transmissions must be made :
- at specific times – usually 48h and 24h before the departure and at time of departure, when doors are closed
- in specific formats PNRGOV, PAXLST,PAXLST CREW, issued from air industry standards, so the state’s recipient system can integrate them.
To easily understand, have a look to the infography of this post
This EU PNR regulation comes in addition to the existing API regulation.
Implemented in 106 states by the beginning of 2022, the “Advance Passenger Information” – also commonly called APIS for API System – imposes to air carriers the transmission of passengers data (slightly different from PNR one) to the state of destination prior to the take-off of in-bound flights. For the European Union states, only inbound flights from extra-schengen/extra-EU countries are generally concerned. This requirement was originally intended for commercial aviation but some countries have extended it to general aviation such as the USA, Canada, Russia, UK or UAE.
Why, both, API and PNR data are requested whereas it seems to provide the same information?
In fact, each regulation has its own objective and own legal foundation, even if they might be merged in the future. API data is initially used to ease immigration and border control by pre-identifying who is transiting or flying into or out of a territory. Whereas PNR data is used by law enforcement for the prevention, detection and investigation of terrorism and serious crime.In other word, for upstream research and investigation of criminals not for immigration checks. Another difference is that PNR messages are sent with more anticipation – up to 48h before flight departure – than API messages and contain different data. Even if, in practice for Business aviation, the content of API and PNR data are pretty much the same.
A bit of history to understand the current state of API-PNR systems deployment
To explain why there are such differences of readiness from one state to another and why some carriers are requested to send their data whereas others don’t, you should understand how states implement those API-PNR data collection.
The implementation history of API / APIS data collection
The collection of Advanced Passenger Information (API) is an initiative that has been created in 2001, immediately after the terrorism attack of 9/11. The USA was the first state to implement it. As well as other countries, the European Union joined the initiative – by adopting the API Directive in 2004.The initial intent of API targeted only commercial aviation, nevertheless it has been extended to General aviation by several states e.g. USA, Canada, Russia, UK or UAE.
The implementation of PNR or PNRGOV data
In 2016, the EU PNR directive was added with the intention to collect the passenger data from ALL air carriers from/to ANY countries. Each EU state has worked hard to implement their PNR system, as each state should implement its own system. They have started their implementation by connecting regular (commercial) airlines operating scheduled flights with the objective to continue the roll-out with non-scheduled flights. As you can imagine, all states didn’t progress at the same pace. This explains why the most advanced states have started to notify Business Aviation to transmit their passenger data whereas others haven’t done it yet.
In addition, as a carrier connection requires exchanges between parties, the state notifies the carriers progressively by small groups, upon their ability to manage the associated workload and typically following a list of priorities established in advance.
Therefore even within the same carrier category (e.g. Business aviation), all carriers aren’t notified at the same time.
API PNR data collection is today largely adopted by states
Since then, main international organizations such as ONU security council and WCO, and industry associations such as ICAO and IATA have helped spur the worldwide implementation of both regulations by including them as “recommended practices” into their guidelines (between 2014 and 2020). The collection of API and PNR passenger data is now considered as a worldwide standard for states and a legal obligation for the transport industry.
As a consequence, lot of countries follow the trend and start or extend their passenger data collection.
All these elements highlight why carriers are notified to comply at different times by states and why states, requesting for passenger data, are growing.
Which states are currently requesting passenger data to General Aviation (Business Aviation, Charter or other small air carriers) ?
A growing number of states are getting ready and are requesting to receive passenger data from non-commercial aviation, in Europe but also outside Europe. As of today, the states already requesting API or PNR data to non-scheduled carriers are : Poland, Luxembourg, Croatia, Germany, Turkey, Greece, Portugal, Italy, Spain, Roumania, Russia, UK, USA, Canada, UAE … this list increases regularly.
In the EU, to initiate the process, member states must send a notification letter requesting the transmission of API-PNR data to the carrier – the carrier is not expected to have proactive action with the authority. So if you are a business jet company and you haven’t received any notification letter from one of the EU states quoted above, you may still have some time to get prepared. But your turn will come… ( (as explained in the previous section)
For non-EU states, the process can be a bit different and proactivity can be the norm.
In the case you are already transmitting data to states, you may continue to manage it manually for the moment. But bear in mind that it will become more and more complex for 2 reasons : the number of countries requesting data is inevitably growing and what is requested is never the same, each state has its own little difference.
Automate your API-PNR data transmission, whatever flight management system you use
At Streamlane, our team has been working since 2016 on these topics. Our deep expertise are recognised not only by air carriers but also by state authorities with which we collaborate daily. As such, we are fully aware of the complexity to comply for general aviation, charters or small carriers.
Therefore we have designed a SaaS platform able to manage this administrative burden on their behalf. Our GOVlink service can be integrated with any flight or dispatch management system. We are already integrated with major flight management systems of business aviation such as FL3XX (review their blog posts intorducing our integration) or Leon Software (review their blog post) and new partnerships are coming.