What is the change? Ireland will soon begin collecting airline passenger data as it moves to implement a 2016 European Union antiterrorism directive.

What does the change mean? Once measures to comply with EU Directive 2016/681 take effect, Ireland will collect passenger information from air carriers for flights arriving from or departing to destinations outside the EU. Ireland will establish a Passenger Information Unit that will collect and process the information, which will be provided to law enforcement agencies in Ireland and other EU member states.

  • Implementation time frame: Ongoing. The measures will be implemented by a statutory instrument at some point between now and May 25, the deadline for implementing the EU directive.
  • Who is affected: Passengers on flights arriving from or departing to destinations outside of the EU.

Background: The EU directive on passenger name record data was adopted in 2016 following high-profile terrorist attacks in Paris, Brussels and elsewhere in Europe. The directive requires EU member states to collect passenger data that air carriers collect in the normal course of their business. The data then becomes available to law enforcement agencies, which can cross-check the information against databases in order to determine if any passengers might have ties to terrorist or organized crime operations. The directive drew criticism from some privacy advocates, but the EU has stressed that it prohibits processing data about a person’s race, ethnicity, religion, health, sexual orientation or political or philosophical beliefs. The directive requires that the data be deleted five years after it is collected.

BAL Analysis: While passengers should note that information they provide to air carriers will soon be collected by Irish officials and other EU member states covered by the directive, the impact on travel procedures will be minimal. The directive does not create any new administrative requirements on passengers themselves and is not expected to cause significant delays for the vast majority of travelers.

This alert has been provided by the BAL Global Practice group. For additional information, please contact

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