Finland Now Requires APIS Submissions for GA
On April 29, 2004, Finland put advance passenger information system (APIS) filing requirements into place for scheduled commercial carriers, as a result of a European Union (EU) directive. However, it was not until September 1, 2016, that APIS reporting became mandatory for general aviation (GA). As this recent regulatory transition was not well publicized, there are GA operators who may not yet be aware of these required reporting procedures.
The following is an overview of what you need to know:
1. APIS for GA mandates
As of Sep 1, 2016, APIS filings have been mandatory for both private non-revenue and charter (non-scheduled commercial) operations to/from Finland. At present, APIS reporting is only applicable for passengers and not for crew, although this may change over time. So, if you’re doing a tech stop or a ferry flight with only crew onboard, these new APIS reporting requirements will not impact you.
2. APIS submissions
APIS submissions for GA differ from those for scheduled commercial flights. Scheduled commercial operators use a UN EDIFACT format whereas private non-revenue and charter operators submit required information to Finnish Border Guard in an Excel format. This Excel document is provided by Finnish Boarder Guard and specific information needs to be submitted. Note that Finnish APIS may be submitted either by your 3rd-party provider, the operator, your ground handler.
3. Applicable GA flights
GA operations are only impacted by APIS filing requirements when the aircraft arrives from or departs to a non-Schengen country and has passengers onboard. For example, APIS would be required for both legs of a Bangor (KBGR)–Helsinki (EFHK)–Dubai (OMDW) trip but only for the inbound leg of a Teterboro (KTEB)-EFHK-Le Bourget (LFPB) trip.
4. Tech stop reporting requirements
GA operators are not required to submit APIS for tech stops in Finland, so long as no one embarks or disembarks. However, there is an exception. If your tech stop in Finland is your first point of entry into the Schengen region, or your last departure out of the Schengen region, APIS must be filed if any passengers are onboard.
5. Lead times for APIS submission
APIS can be submitted as soon as you have passenger information for an applicable flight. However, we recommend filing APIS no earlier than 24 hours prior to the estimated time of arrival (ETA)/estimated time of departure (ETD) so that it does not get lost in the system. It’s mandatory that APIS be filed at least 15 minutes after your departure point from outside the Schengen region and/or 15 minutes after you depart Finland for a non-Schengen country.
6. APIS revisions
If there are any changes to your flight or passengers, APIS must be resubmitted. Even if you’re just removing a passenger whose details were previously submitted, a new APIS filing is necessary. Note that no acknowledgment or confirmation of your APIS submission will be received. The only time you’ll receive any feedback or response to a submission is if Finnish authorities find an error.
7. Errors in APIS submissions
If errors are detected in an APIS submission, Finnish authorities will contact the entity that filed the APIS and ask that corrections be made to whatever information does not match the clearance or applicable documentation. Errors are considered to be anything that does not match up with travel documents, aircraft information or flight schedule. Fines may be applied, on a case-by-case basis and at the discretion of the duty officer, if the operator or entity that filed the APIS does not respond to Finnish authorities with the required correction or an acceptable explanation.
8. Non-submission or APIS
If an operator neglects to file APIS for any applicable flight to/from Finland they have up to two weeks to submit a letter to authorities explaining why APIS was not submitted. After reviewing the letter, Finnish authorities will determine if the response is acceptable or if they will levy a fine.
9. APIS compliance
Be mindful that there’s no grace period in terms of GA operators meeting all APIS reporting requirements. If you’ve failed to submit APIS for any applicable flight to/from Finland post Sept 1, 2016, it will be up to Finnish authorities to levy a fine or to contact the operator to request a letter of explanation. If a reporting requirement has been missed we recommend that you, or your 3rd-party provider, submit a letter of explanation without delay.
If you’re operating a private non-revenue of charter flight to Finland it’s important to know if and when APIS reporting requirements are applicable and to ensure that appropriate submissions are made to avoid potential penalties. Note that changes to current regulations may occur in future — possibly a requirement to add crew to reporting requirements –as determined by Finnish authorities.
If you have any questions about this article or would like assistance for your next trip, contact me at firstname.lastname@example.org.