Industry update, by Paweł Mazur

PNR: Legislative proposal by Polish Senate gives cause for optimism

EBAA is aware several cases are going through the Polish court, but there is no clear answer or timeline to clear the issue. EBAA Member lawyer Paweł Mazur from EBAA member Wardyński & Partners drafted an update.

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On this page PNR

UPDATE 04/02/2022

On 3 February 2022, the President of Poland signed the amendment of PNR rules , including a 2-year suspension of proceedings and enforcement of fines concerning PNR violations.

The law – and the resulting suspension – came into force today, on 4th February. The suspended proceedings will not be resumed until 2024.

EBAA Members should be reminded, however, that the Border Guard remains authorized to prosecute all violations that occur after the law comes into force, beginning with 4th February. Strict compliance is advised.


Legislative works on amending the notorious Polish PNR regulations have taken a surprising turn. The opposition-controlled Senate higher chamber of Parliament proposed a rule suspending the enforcement of PNR violations for two years. This change was unexpectedly accepted by the Sejm lower chamber with full government approval. As of today, the bill only awaits signature by the President, which may occur any day now. A veto is unlikely.

Key points of the bill as adopted by the Parliament:

  • Violations of PNR rules made prior to entry into force of the new law, including the entire 2018-2021 period, will not be prosecuted for two years,
  • All pending cases and fines issued for such earlier violations will be suspended for two years, and new cases will not be opened in that period,
  • The limitation period for fining these violations suspended for two years likewise,
  • The two-year suspension does not apply to violations made after the bill comes into force.

Other changes proposed in the original bill (as reported in the EBAA alert from 18-01-2022) continue to be considered. EBAA advises operators to follow the previously published guidance.


The sudden but welcome development is most likely a response to overwhelmingly negative industry feedback, including direct criticism from industry associations such as EBAA, IATA A4E and ERAA. Although it relieves some pressure from operators, there are two important caveats.

Firstly, this law is not an abolition. The Border Guard will eventually prosecute all prior violations, even if only beginning in 2024.

Secondly, the suspension only applies to prior violations. The Border Guard may prosecute any infractions made after the law comes into force. While less of an issue for operators using a GDS with integrated PNR push functions, others, including most business jets, need to ensure they or their agent strictly knows how to comply with the rules. With their hands now free from the three-year backlog, the authorities may well pick up the pace with the current flights.

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