Hong Kong is set to implement new Advance Passenger Information System (APIS) requirements that will impact business aviation operators starting in April 2025. These changes are part of a broader effort to enhance aviation security through the electronic transmission of passenger and crew data to border control authorities before a flight’s arrival.

While commercial aviation will begin complying in September 2024, business aviation operators have until April 2025 to meet these new standards. Here’s what business aviation operators need to know to prepare for the upcoming changes.

Implementation Timeline

The APIS requirements will be introduced in phases:

• Commercial Aviation: The rollout for commercial flights will start on September 1, 2024.
• Business and General Aviation: Business aviation operators must comply by April 2025, providing time to adapt systems and processes to the new requirements.

Who is Affected?

The APIS requirements will apply to all flights arriving in Hong Kong, including those operated by commercial, business, and general aviation. Specifically for business aviation, this means that operators of private and charter flights arriving in Hong Kong will be required to submit APIS data for all passengers and crew members before the aircraft’s arrival. Flights departing from Hong Kong are not affected by this requirement.

Data Requirements

Business aviation operators will need to provide specific information from passengers’ and crew members’ travel documents, including:

• Full name
• Date of birth
• Gender
• Nationality
• Travel document type, number, expiry date, and issuing authority
• Traveler status (passenger or crew, and whether in transit)

Compliance and Enforcement

The APIS system will require operators to comply with “board” or “no-board” directions issued by Hong Kong Immigration:

• “Board” Direction: This indicates the traveler is cleared to board the aircraft. However, it does not guarantee permission to land in Hong Kong, which remains subject to further immigration checks upon arrival.
• “No-Board” Direction: Operators must prevent the traveler from boarding the aircraft if a “no-board” direction is issued.

Penalties for Non-Compliance

Details regarding penalties for non-compliance with the APIS requirements for business aviation will be defined by the Hong Kong Immigration Department. While specific enforcement measures and dates have not been finalized, business aviation operators are advised to begin preparations well before the compliance deadline of April 2025 to avoid any potential disruptions or fines. Staying proactive will help ensure smooth operations once the requirements are fully enforced.

Preparing for the New Requirements

To ensure compliance with the new APIS requirements, business aviation operators should take the following steps:

• System Integration: Assess and upgrade your systems to handle the collection and electronic transmission of APIS data. Collaborate with your IT and operations teams to ensure necessary technology upgrades are implemented.
• Training: Train your flight crews, ground staff, and operations teams on the new APIS procedures, including data collection, submission processes, and responding to “board” or “no-board” directions from Hong Kong Immigration.
• Coordination with Trip Support Providers: Stay in close contact with your trip support provider, such as Universal’s Trip Support Services Asia team, which is monitoring the APIS rollout closely. They can provide updates, system access information, and detailed guidance on meeting the compliance requirements.
• Stay Updated: Regularly check for updates from Hong Kong authorities. As the implementation date approaches, additional details and operational guidelines will be released, which will be critical to ensuring compliance and smooth operations.

Final Thoughts

The new APIS requirements in Hong Kong are a critical prerequisite for international operations, reflecting a global push for enhanced border security. Business aviation operators should leverage the lead time to ensure compliance and adapt their procedures to meet these evolving standards. Early preparation will help maintain seamless international travel and avoid potential disruptions.