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Navigating Passenger Data Compliance with PNRGOV

Aviation is one of the most regulated sectors in the world, for good reasons, and the complexities within the regulations can be daunting. Paxport Group has worked with European airlines for thirty years and has helped them navigate the many and various complexities by designing technology to address specific needs.

One product we have developed in-house in response to the needs of our customers – PNRGOV.

PNRGOV automates the transfer of relevant data to authorities across Europe in a way which is compatible with the EU directive on passenger data management.

The product is run out of our Stockholm office. It is available as an add-on for users of our other products in our passenger management portfolio but can also be configured to work with third-party non-Paxport systems.

The main consideration is that airlines are responsible for the transfer of data to authorities, irrespective of where the passenger booked. For airlines whose business can be characterised as scheduled, this data can be sourced and sent from the GDS, because the details are held within the GDS because that’s where the PNR sits. The GDS can do the heavy lifting, at a cost, and send the data to the authorities for the airlines in the prescribed format at the prescribed time. Job done.

But when looking at charter airlines, or scheduled airlines which make some seats available to tour operators, a gap emerges – the booking details are not held by the airline but by the tour operator’s booking engine, but the airline is still responsible for transfer of information.

The penalties for non-compliance start with a fine but could in certain cases lead to operating licences being withdrawn or aircraft confiscated – unlikely but not impossible. This is because, while the directive is an EU initiative, the directive mandates that all member states incorporate the requirements within national law. Different member states might take a different approach to enforcement, although the official documentation insists that the fines be “effective, proportionate and dissuasive.”

The application of an EU-wide directive at a national level adds another layer of complexity to the transfer of data.

The directive has led to each member state having its own “Passenger Information Unit” as the designated and exclusive collector of the data. The PIU distributes the information to the relevant national authorities.

This means an airline (or the partner they’ve outsourced this to) has to make 27 different connections to different systems using different approaches and with a different approach to integration.

The national application of an EU wide directive has other implications. Most PIUs request two-three data pushes – usually 48-24 hours before departure which often comes from the passenger management systems and another one after all passengers have boarded which comes from the DCS. But the directive also demands that all the data comes into a member state’s PIU from the same source.

Again, for GDS-based scheduled airlines this is relatively straightforward because the data come from different parts of the same business.

Paxport works with charter airlines and takes responsibility for being the approved source. We take ownership of managing the technical connections as well as the face-to-face conversations with PIU staff ahead of the integrations.

For our customers we can pull the data from the passenger management system for the first data push, and then convert the data that we source from the ground handlers and/or the DCS so that it can be overlaid onto the data already sent. For PNRGov users who are not within the Paxport ecosystem, we can convert the data from whatever system they use into the format required by the PIUs.

An EU-wide directive which gives member states the chance to personalise the directive for their own needs is complicated enough. But there is yet another layer to consider for European airlines who fly to destinations outside the EU. Post-Brexit this includes the UK.

Within the directive there are many protocols in place for the transfer of data required under the EU directive to countries which are not bound by this specific legislation. Charter airlines are less exposed to this than scheduled because passengers on a charter flight tend to be citizens of one nation. Scheduled airlines potentially have more nationalities on board, and this is another area of passenger data management where a GDS can leverage its scale and raise some revenue for itself by helping its airline clients.

Airlines operating in Europe have no choice when it comes to rules around the transfer of passenger data. For many carriers, complying with the rules is embedded into the commercial terms of their GDS contract. For others, the choice is limited to either bring the responsibility, cost and pressure of complying in-house, or find a partner with the experience and expertise to manage this process seamlessly. Paxport Group is ideally placed to be the partner – get in touch with us HERE to find out more.

NDC is good to go

It might come as a surprise to some, but Paxport Group’s distribution platform PaxFaB has made NDC content available to agents, operators and resellers for more than six years. Early 2017, we became one of the first tech suppliers – outside the GDSs – to be certified by Lufthansa Group as part of its NDC strategy.

Since then we’ve kept a close eye of NDC, building up our list of capability certifications with IATA covering the major NDC requirements across order, pay and shop.

Our take on NDC is based on the conversations we’ve had and our experience with airlines and resellers. We’ve heard the industry rhetoric, read the press releases about what NDC is capable of doing in the future (which gloss over the limitations of what it is capable of doing at the time. The over-enthusiastic promotion, by some airlines and some tech vendors, of something that was not ready put off many agents, operators and resellers.

Instead, many third-party sellers sat back and waited. As NDC matured slowly, eventually the mood shifted. For the past 18 months or, third-party sellers were thinking not if I should get into NDC, but when do I make the move, how can I minimise the disruption to my current working practices, who can I work with and what – in practical terms – can I do with this new NDC standard.

In many ways, sellers of airline content are still at the mercy of what the airlines want to do with NDC (and their long-term plans for legacy technology). The initial impetus for NDC – drive direct bookings, reduce third-party sales – has given way to a more balanced approach where selling seats through agents and operators is now seen by airlines as a good thing.

Airlines are now aware that if they want to sell seats through the trade then they also need to give the trade ways to service these bookings. But to be honest, from a Paxport perspective the NDC headwinds have never been about the difficulty selling seats – its about how can we configure our distribution platform so that agents and operators can service that seat booking once its been sold, and how can the platform add (and then service) any ancillaries or add-ons.

Servicing is vital for anyone wanting to sell full-service carriers, and, by extension, anyone looking to get into the corporate travel.

A distribution platform which has its roots in flight aggregation should not be overly focused on the schema and standards. A booking is a booking, and a distribution platform’s role is to normalise the process so that agents and tour operators can use the same workflow whether it’s channelled through EDIFACT, or XML, or JSON, or other schema in the market.

Normalisation is a core feature of our platform, and many PaxFaB users are already consuming content via the NDC API without realising it. This shows that NDC can be embedded into existing processes, with the benefits of NDC surfaced without additional direct and indirect costs.

As mentioned, NDC gives airlines control, so the benefits to resellers will vary according to what incentives the airline – lower fees, lower fares, more content to sell. Today, (most) airlines see agents more as a friend not a foe, so the benefits of adopting NDC will grow over time as more airlines offer it, more agents consume it, more travellers book through it, more revenue is generated.

But while we’re quite positive about NDC, it’s not the silver bullet that everyone thought it was. It is a standard, but its not consistent – look at what “Airline A” is offering through NDC compared with “Airline B”. And with many airlines using different versions of NDC, there are some technical issues which agents need to be aware of – or which the distribution platform used by the agent needs to be aware of.

Overall, our recommendation is that agents and operators can ignore yesterday’s hype and focus on today’s reality. NDC is nothing to be nervous about providing you have a partner who understands airlines and distribution and is already doing NDC.

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