France introduces API PNR collection for the commercial business aviation

France is extending Advance Passenger Information (API) and Passenger Name Record (PNR) reporting requirements to commercial business aviation flights arriving in or departing from French territory. With enforcement measures applying from 1 October 2026, operators should review their procedures and ensure that the necessary reporting capabilities are in place.

Under Article L232-7 of the French Internal Security Code, API and PNR data must be transmitted to the French National Travel Data Agency (ANDV) for commercial business aviation flights to and from French territory.

France will apply strict measures for non-compliance starting 1 October 2026, giving operators limited time to review their processes and implement the necessary reporting capabilities.

France’s requirements in practice

• Obligation apply to commercial flights (private flight are exempted)
• API and PNR data must be submitted for passengers only (Crew data is currently not required).
• Data must be transmitted at:
  • 48 hours before departure (H-48)
  • At departure (H0)

Geographical scope

• All arriving and departing international flights to/from French territory. Intra-Schengen routes are subject.
• French territory includes the French overseas territories.

While domestic flights operated within mainland France are not subject to API/PNR reporting, API/PNR transmissions are required for flights:

• between mainland France and a French overseas territory;
• and between French overseas territories.

French territory

The French overseas territories include Guadeloupe, French Guiana, Martinique, Réunion, Mayotte, Saint-Barthélemy, Saint-Martin, Saint-Pierre and Miquelon, French Polynesia, Wallis and Futuna, and New Caledonia.

The introduction of API-PNR replaces the requirement for GenDec submissions to Police at station for commercial business flights

Do API PNR declaration obligations change customs and immigration procedures? 

No, the introduction of API/PNR reporting does not change the existing customs and immigration procedures.

Operators should remember that API/PNR reporting and customs formalities are two separate obligations.

Submitting passenger data does not replace customs or immigration requirements. If the final destination airport does not provide customs or border-control facilities, operators must still make their first landing at an authorised airport of entry before continuing the domestic leg.

Exemptions

• The following operations are not subject to these API/PNR reporting requirements:
• Private (non-commercial) flights
• Flights carrying only crew eg positioning (ferry), cargo and maintenance flights
• Medical evacuation flights
• Military flights

However, exempt flights may still be subject to other reporting obligations, i.e.General Declaration (GenDec) requirements.

Consequences of non-compliance from 1 October 2026

Failure to provide the required API and PNR data without reasonable excuse constitutes an offence under Article L.232-7 of the French Homeland Security Code.

The legislation provides for administrative penalties of up to €50,000 per flight arriving in or departing from France where the required data has not been transmitted.

As with any regulatory programme, operators are encouraged to ensure that appropriate procedures and reporting capabilities are in place before the enforcement period begins.