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Regulatory Hot Topics

Operators Must Ensure Compliance With API/PNR Requirements

Industry Challenge:

Failure to comply with complex and varying passenger entry procedures around the globe can mean hefty fines and other regulatory actions against business aviation operators.

NBAA Response:

NBAA urges business aviation flight operations to work with trusted partners who are able to research and verify API/PNR requirements at their destinations.

With countries bolstering aviation security efforts, or launching new programs to identify those crossing their borders, operators must be well-versed with differing advance passenger information (API) and passenger name record (PNR) procedures and any new passenger regulations.

For example, the European Union will introduce an Entry-Exit System/European Travel Information and Authorization System (EES/ETIAS) to improve passenger screening, imposing new obligations for carriers. The UK recently introduced the Electronic Travel Authorization (ETA) and shortened the submission deadline for the General Aviation Report (GAR), which now requires flight and passenger information to be submitted at least 2 hours before departure.

Each non-compliant flight may incur a potential fine of £10,000. While most fines to date have been waived, Hélène Dubos, head of marketing for Streamlane, warns that a harder line is coming. “That is a real risk,” she said. “My advice to operators: Don’t take any chances. The flexibility we’ve seen won’t last.”

“Each member state will decide what border crossings and airports will use the electronic system,” said Rick Snider, director of contracts and compliance with Flight Pro International. “This phased approach will require stamping passports even with the electronic system in place.” Delays with adding those capabilities and equipment at airports and other entry points will mean a lack of uniform procedures at first. The EU’s EES data will be managed through the eu-LISA technical infrastructure.

The introduction of such systems are impacting and changing the way carriers vet their passengers. Once those validation systems are in place, “anyone who touches the custom zone on the other end will have the appropriate visas,” said Adam Hartley, global regulatory services team lead at Universal Weather and Aviation. “They’re taking the guesswork out of the process.”

“Procedures may vary significantly, so if you manage that yourself, you need one person dedicated to digging into all that legislation.”

Hélène Dubos, Head of Marketing, Streamlane

Other countries, including Kazakhstan and Kenya, have implemented strengthened passenger entry requirements, with Hong Kong launching its API/PNR program in April. Dubos urged operators to thoroughly research requirements well in advance.

“This is about fighting criminality and strengthening border control,” said Dubos. “Procedures may vary significantly, so if you manage that yourself, you need one person dedicated to digging into all that legislation.”

“Whether you work with a service provider or directly with an FBO or local company at the destination, it is absolutely important to know what the requirements are and how to meet them,” Snider said. “A passenger who fails to mention a new passport, for example, can mean significant problems on the ground.”

“Whether it’s a flight department employee or third-party planning provider, you must work with someone you trust,” said Hartley.

Review NBAA’s international operations resources at nbaa.org/intl.

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