Airlines UK  Written evidence (EBM0007)

Airlines UK is the association for UK airlines, with members including 2Excel, Ascend Airways, AirTanker, British Airways, DHL, Eastern Airways, easyJet, European Cargo, FedEx,, Loganair, Ryanair, TUI Airways, Titan Airways, UPS, and Virgin Atlantic.

We are pleased to provide evidence to the Justice and Home Affairs Committee short inquiry on Electronic Border Management Systems.

  1. What are the potential drawbacks of the ETA and what mitigations might be put in place to address these? What lessons can be learned from the experience of other countries with similar schemes?

UK airlines support the introduction of and rationale behind the new ETA scheme, and are working with the Government and departmental officials to enable its successful rollout.


We are, however, concerned about the negative impact of requiring all passengers transiting through the UK to obtain a new ETA. This requirement will place the UK at an immediate competitive disadvantage compared to its European neighbours, where the equivalent EU system - the European Travel Information and Authorisation System (ETIAS) - will not apply to transiting passengers who do not cross the border.


Transit passengers can make up a high percentage of passengers - ranging from 20% but up to over 50% on some international routes – and are a critical part of aviation’s ‘hub and spoke’ model. In practice, passengers that need to connect onto secondary services will have a choice of using UK or EU hubs and this offer of connections and competition with other hubs is a fundamental part of our business models and the reason that so many aviation jobs are based in the UK. Several million travellers who do not currently require a visa or other form of additional authorisation to transit through the UK will now require an ETA even if remaining airside (i.e. not passing the UK border). The ETA would add £40 to the cost of a trip for a family of four, adding a barrier to travel through an additional administrative burden, making transiting through the UK much less competitive than using an alternative EU hub. The shift of any significant percentage of travellers on these routes to European hubs ultimately risks damage to the UK’s position as a global aviation hub.


We are, therefore, calling on the UK Government to commit to applying the same exemptions as apply to the ETIAS to the ETA scheme (including airside transit visitors) to ensure that risk is assessed on a country-by-country basis.


  1. What impact will the schemes (EU’s Entry/Exit System (EES) and the Electronic Travel Information and Authorisation System (ETIAS) have) in respect of travel between the UK and the EU?

The European Entry/Exit System (“EES”) project involves the electronic recording and storage of data such as the date, time, and location of entry and exit for travellers crossing the borders of EU member states, specifically within the Schengen area. Ultimately, the introduction of the system should be beneficial in the long term, making it quicker to enter the EU.

UK airlines continue however to have concerns about the implementation of this new system, both in terms of process and, consequently, timeline. The implementation date has been postponed on three occasions due to the complexity of the programmes involved and the lack of readiness of border authorities across the EU. The EU now expects a ‘go-live’ date this year potentially in October 2024. It is welcome that the implementation date has been moved to avoid coinciding with the peak, summer season for travel. Nonetheless, there have been ongoing delays to providing environments for airlines to test the system against, and airlines continue to raise concerns with eu-LISA (which is developing the IT system) that the anticipated process for testing and implementation remains ultimately unclear. What is known of the process and requirements appears unnecessarily laborious, resulting in lower confidence that implementation can be delivered on time. 

Significant work will also have to go into passenger communications ahead of the launch of the new system to ensure customers are ready and know what to expect and are not put off from travelling, and to ensure that any delay impact at EU entry and exit borders is minimised, particularly during initial biometric enrolment of passengers for EES on arrival into the EU for the first time after launch (potentially a three-minute biometric registration process per passenger). This is likely to be most acute in smaller, seasonal airports, where the physical airport infrastructure can be more limited but that can experience spikes in arrivals during certain times of the year. For example, with EES biographic details such as fingerprints and photos need to be taken at the border on entry to register a passenger, this will need to be managed effectively in circumstances where, for example, three UK flights arrive might arrive at the same time at a smaller airport.

To minimise any potential disruptions arising from the implementation of EES for the operators and passengers travelling to the Schengen Area, the UK government should take a proactive role in creating awareness about the new system. Although operators can assist in promoting the awareness campaign, the DfT, Border Force, and Home Office communication teams should lead the messaging campaign. Additionally, the UK government should raise awareness about ETIAS, which is scheduled to be implemented six months after the introduction of the EES.

Given the potential impact on UK nationals at the launch of the scheme, it is important that the UK continues to work constructively with its EU counterparts to ensure rollout can be delivered as seamlessly as possibly, without undue delays or disruption to passenger journeys at the launch.  


14 March 2024