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ICAO Annex 9 and the PNR SARPs

Last checked 24 October 2026 · 6 sources

Short answer

Annex 9 (Facilitation) to the Convention on International Civil Aviation 1 holds ICAO Standards and Recommended Practices (SARPs) on facilitation, including passenger data exchange 2. Its chapter on Passenger Data Exchange Systems covers API, PNR and a Passenger Data Single Window 2. The ICAO Council adopted Amendment 28, the PNR SARPs, on 23 June 2020 3. It took effect on 30 October 2020 and became applicable on 28 February 2021 3.
Body
International Civil Aviation Organization (ICAO) 3
API Standards
9.7 and 9.8, from Amendment 26 2
PNR SARPs
Amendment 28, 11 Standards and 6 Recommended Practices 2
Adopted
23 June 2020, 220th Session of the Council 3
Applicable
28 February 2021 3
Status
Live. Applicable since 28 February 2021 3

What Annex 9 is

Annex 9 (Facilitation) is an annex to the Convention on International Civil Aviation 1. It contains ICAO Standards and Recommended Practices on facilitation, including passenger data exchange 2.

Recent amendments created a separate chapter titled Passenger Data Exchange Systems. It covers API, PNR and the Passenger Data Single Window under Standard 9.1 2. The EU Council Decision of 2019 says the PNR SARPs sit in Parts A and D of Chapter 9 1.

The API standards

Standard 9.7 requires each State to establish an API system, covering batch API 2. Standard 9.8 requires every API system to be supported by appropriate legal authority and to be consistent with internationally recognised standards 2.

The ICAO EUR/NAT office says these two Standards came from Amendment 26, largely driven by UN Security Council resolution 2178 (2014) 2. Amendment 26 added a Recommended Practice that encourages States to consider interactive API. It is not a Standard 2.

How the PNR SARPs were made

ICAO says UN Security Council resolution 2396 (2017) urged it to establish a standard for the collection, use, processing and protection of PNR data 3. The Council of the EU set the EU position for the ICAO Council on 28 November 2019 1.

  • March 2019: ICAO's Air Transport Committee set up a PNR Task Force 3.
  • 13 to 16 January 2020: Eleventh Meeting of the Facilitation Panel (FALP/11) 3.
  • 7 February 2020: The Air Transport Committee endorsed the proposals 3.
  • 23 June 2020: The Council adopted Amendment 28 at the Tenth Meeting of its 220th Session 3.
  • 17 July 2020: States were notified by State letter EC 6/3 20/71 3.
  • 30 October 2020: Amendment 28 took effect 3.
  • 28 February 2021: Amendment 28 became applicable 3.

What the PNR SARPs require

Amendment 28 includes 11 Standards and 6 Recommended Practices on PNR 2. Standard 9.24 sets the baseline commitment for States to develop the capability to collect, use, process and protect PNR data 2.

Standards 9.24, 9.25, 9.26, 9.29 and 9.31 are subject to audit under the ICAO Universal Security Audit Programme 2.

IATA, the airline industry association, asks governments to use the PNRGOV message format and to set retention periods and deletion rules 4.

Work with the UN

ICAO signed a Memorandum of Agreement with the UN Office of Counter-Terrorism to help Member States collect and analyse API and PNR data 3. ICAO is an implementing entity of the UN Countering Terrorist Travel Programme, launched on 7 May 2019 5.

Resolution 2396, paragraph 12, decides that Member States shall develop the capability to collect, process and analyse PNR data, with full respect for human rights 6.

Common questions

When did the ICAO PNR standards become applicable?

Amendment 28 to Annex 9 became applicable on 28 February 2021, after taking effect on 30 October 2020 3.

Is interactive API an ICAO Standard?

No. It is a Recommended Practice added by Amendment 26 2.

Which PNR standards are audited?

Standards 9.24, 9.25, 9.26, 9.29 and 9.31 are subject to audit under the Universal Security Audit Programme 2.

Why did ICAO write PNR standards?

ICAO says UN Security Council resolution 2396 (2017) urged it to establish a PNR standard 3.

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Sources

  1. legislation.gov.uk: Council Decision (EU) 2019/2107 on the position to be taken on behalf of the European Union within the Council of the International Civil Aviation Organization as regards the revision of Annex 9 (Facilitation) to the Convention on International Civil Aviation in respect of Standards and Recommended Practices on passenger name record data (28 November 2019)
  2. ICAO EUR/NAT Office: Newsletter #2 Annex 9 Facilitation Passenger Data Exchange System (2021)
  3. ICAO Annual Report 2020: Contribution to Global Security, Counter Terrorism and UN Security Council Resolutions (2020 report)
  4. IATA (industry association document): Implementation of API, iAPI and PNR programs, Key Considerations for Governments, V1 (2026)
  5. UN Office of Counter-Terrorism: Summary, Countering Terrorist Travel Programme (accessed 24 October 2026)
  6. UN Meetings Coverage and Press Releases: Security Council Urges Strengthening of Measures to Counter Threats Posed by Returning Foreign Terrorist Fighters, Adopting Resolution 2396 (2017) (21 December 2017)

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