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EU PNR Directive
PNR Data Format and Transfer Protocols
                                                                                                                                                                                                         September 2016

The recent adoption of the EU PNR Directive (EU Directive 2016/681) implies that airlines will have to comply with, potentially, 28 different national PNR data collection systems within the next two years.

In this context, the definition by the European Commission of the common protocols and supported data formats for the transfer of PNR data by air carriers (as per Article 16 of the Directive) is of utmost importance to the industry and Member States. For airlines, this will limit the costs and administrative burden of compliance in each Member State. At the same time, Member States will also be able to connect easier and faster to all the impacted airlines.

Based on the work of the PNRGOV Working Group and on the feedback received from our member airlines, IACA (International Air Carriers Association), IATA (International Air Transport Association) and A4E (Airlines for Europe), would like to submit the following comments on PNR data formats and protocols:

Data format

The two formats of the PNR GOV message (PNRGOV EDIFACT and PNRGOV XML) have been developed jointly by governments, airlines and service providers to avoid investments in multiple and parallel systems. These data formats have been recognised and endorsed by ICAO and WCO as international standards for the transmission of PNR data. Any new requirement or version updates are defined through the API/PNR Contact Committee1 which involves WCO, State representatives, ICAO and IATA.

As a result, all airlines, regardless of their model of operations, already support the PNRGOV EDIFACT format. This format is also being used by all the authorities that are already receiving PNR data. PNRGOV EDIFACT should therefore be the format adopted for PNR data transfer.
Acknowledging that airlines are also looking into future developments of their IT systems, PNRGOV XML could be offered as another possible format (in addition to EDIFACT). However, it is important to note that use of the XML format is currently supported by only a very limited number of airlines.

Transfer protocols

Recent industry analysis (2) shows that MQ Series messaging is supported by 71% of IATA member airlines transmitting PNR data, while Type B is supported by 60% of them. All the countries in the world which have implemented Passenger Data Programs are also supporting MQ Series messaging and/or Type B. In order to allow for a swift implementation of the PNR Directive requirements, it is therefore essential that both MQ and Type B are allowed as available communication protocols.

As both industry and governments are looking into modernizing their IT systems and introducing new technologies as part of major business transformation, we understand that in the medium-to-long term, new transfer protocols can be deployed to meet both the needs of governments and of airline operators. The industry is ready to actively cooperate in the identification of suitable protocols, which shall be done in the framework of the PNRGOV Working Group, under the umbrella of ICAO and the WCO, to avoid a patchwork of transfer protocols at international level.

Conclusion

The standard PNR data formats and transfer protocols mentioned above, are successfully used today by a wide number of authorities. Such data formats and protocols have been well developed, tested, and have reached a high degree of maturity over the years. EU Member States would benefit from the use of these well-established formats and protocols, which would allow for swifter connectivity to airlines and would avoid unnecessary new development costs. Message stability would also mean fewer errors in the transmissions.

For airlines, the use of standard formats and protocols will, not only allow faster compliance, but will also reduce the burden of the development of 28 different standard messages needing corresponding connectivity.

Based on the comments above, and in the interest of a rapid implementation of the PNR Directive, the industry is calling upon Member States and the European Commission to follow existing and internationally agreed upon PNR data formats and to provide for the use of currently deployed transfer protocols. Should the EU impose different standards and/or protocols other than the ones mentioned above, this would imply significant delays and cost for airlines to adapt their IT systems, and would be misaligned with established ICAO and WCO standards.

Harmonization of requirements amongst the 28 EU Member States will also play a key role in the swift implementation of the Directive. It is therefore important that all Member States offer airlines, the same and complete list of all possible data format and transfer protocols options.

Finally, the airline industry would like to highlight once again that the most preferable and efficient option remains the implementation of a single PNR window and processing system for all 28 EU Member States, which would facilitate data sharing and EU-wide coordination, while avoiding duplicative transfers of data. In that regard, we encourage Member States to consider the option offered in Article 4 para.4 of the EU PNR Directive.

Footnotes:

1. For more information : http://www.wcoomd.org/en/about-us/wco-working-bodies/procedures_and_facilitation/wco_iata_icao_guidelines.aspx

2. Data Source: ‘’IATA PNR Survey’’ conducted during July/Aug 2016. 95 IATA member airlines worlwide were surveyed, with a 42% response rate.