International Air Transport Association, Board of Airline Representation UK and Airlines for America — Written evidence (EBM0008)

1. General Industry View on Electronic Travel Authorizations

• Industry encourages states to make the best use of modern facilitation technologies, principles and processes to relax their visa requirements.
• industry invites national authorities to enhance border security while simplifying border crossing and removing unnecessary barriers to travel.
• According to a study published by the World Travel and Tourism Council working with Oxford Economics, the average impact from different policy changes in travel authorization, ranges from 8.1% increase in travel demand as a result of introducing new types of visas such as digital authority to travel to 16.6% growth in travel demand as a result of visa-free travel.
• The efficient use of border control technologies, principles and processes can help move toward a more open yet secure regime to boost travel, trade and tourism and thereby national economies.
• There are several modern facilitation tools and processes that can perform some of the functions of travel authorizations. Tools and processes available to vet and identify travelers include API/iAPI, registered traveler programs (RTPs), ePassports, travel portals, digital wallet, electronic declaration, ABC, and biometrics.
• Industry encourages states to make the best use of these tools and processes to relax their travel authorization requirements to increase their country's attractiveness and competitiveness.
• When a country imposes visa requirements for specific nationalities or decides that additional information on visa-free nationalities is required, electronic travel systems (ETS) for the issuance of eVisas and electronic travel authorizations (eTAs) are more efficient, from a facilitation and border control perspective, than traditional counterfoil or stamp visas
• There are currently fewer than 10 countries worldwide that have rolled out an ETS with iAPI integration. Over 60 states have implemented a travel authorization system where the application and/or issuance are performed online. In the latter case, given the absence of an iAPI system, verification by airlines has to be performed manually, and on documents that are not subject to harmonization. Therefore, eTA projects should consider the digitalization and automation of the three key underlying processes, i.e., application /lodgement by the passenger; acceptance and issuance by authorities and verification by airlines and other third party.

2. Key considerations on Electronic Travel Authorizations

• Engagement with industry stakeholders: Early and continuous engagement with industry key players, such as Call for Evidence on Electronic Border Management, is essential to ensure buy-in, swift implementation and recognition of requirements. Understanding and mapping the impacts of border modernization processes of industry’s operations is key to success of such endeavor.
• Departure procedures: ETA should provide carriers and travellers with clear information and robust operational and outage procedures. In the case of Entry Exit System / European Travel Information and Authorisation System (EES/ETIAS), and due to the lack of a fully-fledged iAPI, carriers could be subject to run extra manual checks on travellers, beyond the implementation of the iAPI, defeating automation and digitalization efforts by the airline industry. These duplications of checks will be cumbersome for both travellers and carriers. Furthermore, this will impact departing procedures from origin countries such as UK.
• Border control waiting time/s and impact on Minimum Connecting Times (MCT): MCT is a key factor in the commercial strategies of network carriers. Successful strategies attract international connecting traffic, which directly benefits both the hub carrier and the airport. Airports, airlines and border authorities should negotiate Service Level Agreements (SLAs) to ensure border controls do not constitute a bottleneck in airport operations.
• UK ETA for transit travelers: this requirement will place the UK at an immediate competitive disadvantage compared to its European neighbours, where the equivalent EU system - the ETIAS - will not apply to transiting passengers who do not cross the border. Alleviating solutions should be explored.
• UK ETA for deadheading crew: Deadheading crew are working crew on rotation and therefore, should be treated the same as duty crew as they are in many contexts. From a practical perspective, the rule would require all crew members to be constantly in possession of a valid ETA because it is difficult to anticipate when they will be rostered as Deadhead crew to the UK. This requirement will be difficult to manage with an electronic travel permission which only has a two-year validity period. Unlike a traditional visa foil crew members will be unable to provide substantiated proof to the carrier of the ETA approval and ensuing expiry date. There is also a lack of clarity on how deadhead crew apply for and pay for the ETA. The use of personal funds to pay for work related travel documents may not be supported by carriers and will drive additional complexity for the industry.
• Public communication campaign: a clear and comprehensive official communication campaign on the new requirement ahead of its launch and continuous communication to passengers/public is crucial. When there are ETA exceptions, authorities may consider additional communication to passengers covered by those. This applies both to UK-driven ETA and other countries' ETA impacting UK nationals (i.e. EES/ETIAS). In the case of EES, it is foreseen that the ‘’phased approach’’ to incorporate visas in scope, may be a potential source of increased confusion among the travelling public with subsequent impact on travelers, carrier operations on departure and border procedures arrival into Schengen.
• Support centre to carriers: as soon as ETAs are operational, carriers should be provided with an official support centre from authorities, available 24/7. It shall be staffed appropriately as per the corresponding functions (i.e. mostly immigration/travel documentation and IT). The center should have access to relevant authorities’ databases, systems and/or information as applicable, to provide complete and accurate support, including authorization to board and override capabilities. This should contribute to deal with refusals and-or exceptional cases and redirect travelers accordingly.
• Support centre to passengers: a dedicated 24/7 hotline should be set up to assist passengers throughout their application process and/or to check their status, as well as if they require assistance when denied boarding while meeting travel document requirements.
• Interoperability: authorities should not introduce non-interoperable solutions.  While the mix of electronic and manual processes can facilitate the obtention of visas, the verification process by airline staff is cumbersome. Despite the presence of an iAPI system in the UK, options to provide travellers with a proof of their eTA, beyond just an email, should be considered. This may be useful in case of system outages, planned maintenance and for third party verifiers, such as other third country border agents. Such a proof is as well convenient for passengers who may refer to it in case of doubt about the presence and validity of their eTA.
• Integration with contactless: when implementing modern travel authorizations, consideration should be given to their integration with a contactless travel environment.
• Direct interaction between Govt and travellers:  direct interaction between and travelers via for example digital travel platforms for travellers to directly provide information to governments related to immigration, security and health requirements is an ideal solution to avoid airlines being data brokers. Experience shown during COVID with Government digital health platforms, reveals the important uptake of this pre-travel verification tool which suggests that it is a globally scalable solution.

March 2024