ERA response to European Commission survey on API

4 April 2023: ERA recently responded to the European Commission survey on API, raising the major concerns of the industry and our members regarding the new proposals from the Commission published in December 2022. The association has been working with IATA and A4E to prepare a joint industry paper and to organise a workshop with experts from DG HOME.

In December 2022, the European Commission adopted two proposals to strengthen the use of Advance Passenger Information (API) data as a key action in the EU Security Union Strategy.

The new texts will introduce uniform rules on API data collection, mandatory API data collection for the purposes of border management and mandatory API data collection for law enforcement purposes.

The proposals have already entered the codecision process. The LIBE Committee is responsible for analysing such regulations, but the rapporteur still need to be appointed.  

ERA has been working with other industry associations (A4E and IATA) to prepare a joint position paper. From this basis, we raised the main concerns of the members over the consequences and lack of clarity and details in the proposals.

ERA drafted a response to the Commission survey raising four majors concerns: the impact over the passenger experience with additional checks and boarding time, reservations regarding the proposal to mandate by law the method by which carriers should collect API data, the need of carriers and national authorities collaboration for a balanced and flexible approach and a consistency on crucial elements for operators to set up their systems and procedures and a unique approach for all inbound flights.

Along with the response, ERA, IATA and A4E are sharing the joint position paper to stakeholders and preparing meetings with institutional actors to spread our concerns.

To discuss the new proposals, the associations would like to invite their members to a workshop on API with Commission representatives that will take place on 14 April.

Experts from DG HOME will respond to the questions from the airlines and in particular:

• Co-existence of API/EES/ETIAS/PNR Regulations
• Scope of API regulations
• Potential disruption caused by a lack of clarity on Data Correction/Completion/Update/Deletion
• Penalties for non-compliance

The meeting will take place in IATA Brussels Offices, and it will be possible to attend either remotely or in person.