New Requirements for Polish Passenger Name Records (PNR)

Poland has transposed into national law EU Directive 2016/681 on the processing of passenger name records1 (PNR). The requirements in the law are applicable to air operations to and from the sovereign territory of Poland.FOR WHAT FLIGHTS MUST PNR DATA BE SUBMITTED?Flights that meet all the below criteria are required to comply with the Polish PNR Act, irrespective if the flight is operated as a scheduled or an unscheduled operation:

• conducted by an air carrier entitled to perform air transport of passengers, and organized in connection with the air carrier’s business;
• carrying passengers;
• from which an air carrier receives benefits (e.g. carried out for remuneration); and
• during which the border of a country is crossed and the departure or landing of an aircraft happens on the territory of Poland.

This means that for flights from which the air carrier does not receive benefits - like owner flights and corporate flight departments, but may be conducted by an air carrier entitled to perform air transport – no PNR data have.HOW TO SUBMIT PNR DATA?Air carriers operating non-scheduled flights can transmit PNR data directly to the PIU using the “Air Carriers Portal” (https://ksipnr.strazgraniczna.pl/login ) This portal is intended for every air carrier, including the ones that do not have an ICAO or IATA operator code and therefore are unable to submit data using EDIFACT or XML formats.WHEN TO SUBMIT PNR DATA?Air carriers subject to the PNR data-submission requirements must submit information in the following timeframes:1) from 48 to 24 hours before the planned start of the PNR flight and2) immediately upon completion of the check-in and boarding of passengers, when passengers are no longer able to board or leave the aircraft before it starts (actual time of departure -- ATD).