Cruise and ferry passenger data: manifests, registration and API rules
- International standard
- IMO FAL Convention, in force since 1967, with FAL Form 6 as the passenger list 1,2
- Maritime single window
- Mandatory under the FAL Convention from 1 January 2024 1
- EU passenger registration
- Directive 98/41/EC, amended by Directive (EU) 2017/2109 of 15 November 2017 5
- EU reporting framework
- Directive 2010/65/EU, repealed from 15 August 2025 by Regulation (EU) 2019/1239 3,4
- US APIS retention
- No more than 12 months in APIS from collection 8
- UK registration rule
- Merchant Shipping (Counting and Registration of Persons on Board Passenger Ships) Regulations 1999 9
The international standard: the FAL Convention
The Convention on Facilitation of International Maritime Traffic (FAL Convention) is the IMO treaty that standardises the documents ships give to authorities on arrival and departure. IMO says the Convention has been in force since 1967 and that a maritime single window for data on crew, passengers and cargo is mandatory under it from 1 January 2024 1.
The FAL forms are listed in the Annex to EU Directive 2010/65/EU. They include FAL Form 5, the crew list, and FAL Form 6, the passenger list 2. A single window is one electronic entry point where a ship reports information once and the relevant authorities share it 3.
EU rules: counting and registering passengers
Council Directive 98/41/EC is a safety rule. It exists so that rescuers know who is on board a passenger ship if something goes wrong. Directive (EU) 2017/2109 of 15 November 2017 amended it, and Member States had to transpose the changes by 21 December 2019 5.
Before a passenger ship departs, the number of persons on board must be communicated to the master 5. Where the distance to the next port of call exceeds 20 miles, the company records more detail 5. The data must be collected before departure and reported no later than 15 minutes after departure 5.
EU rules: single window reporting
Directive 2010/65/EU of 20 October 2010 set the reporting formalities for ships in EU ports. Article 5 required Member States to accept electronic reports through a single window no later than 1 June 2015 3. Its Annex lists the persons-on-board information under Articles 4(2) and 5(2) of Directive 98/41/EC, border checks under the Schengen Borders Code, and FAL Form 6 2.
Regulation (EU) 2019/1239 of 20 June 2019 set up the European Maritime Single Window environment. It repealed Directive 2010/65/EU from 15 August 2025 and applies from that date 4.
United States: vessel APIS manifests
US Customs and Border Protection (CBP) requires an electronic arrival manifest for commercial vessels under 19 CFR 4.7b. The timing depends on voyage length. For voyages of 96 hours or more, the manifest is due at least 96 hours before entering the first US port. For voyages of 24 to 96 hours, it is due before the vessel departs. For voyages under 24 hours, it is due at least 24 hours before arrival 6.
Departing vessels must send a manifest no later than 60 minutes before departure from the United States under 19 CFR 4.64 7. Neither rule applies to a vessel operating as a ferry. The arrival rule defines a ferry as one carrying passengers or vehicles between places no more than 300 miles apart 6,7.
The Advance Passenger Information System (APIS) notice of 13 March 2015 says commercial air and vessel carriers provide the data. It says vessel data includes the vessel name, flag country and IMO number 8.
- Full name, date of birth, gender, citizenship and country of residence 6
- Status on board, travel document type, and passport number, country of issue and expiry date where a passport is required 6
- US address, with exceptions for US citizens, lawful permanent residents, crew and people in transit 6
- PNR locator, if available 6
- Foreign port where travel to the US began, port of first arrival, vessel name, flag, IMO number and arrival date 6
United Kingdom
The Merchant Shipping (Counting and Registration of Persons on Board Passenger Ships) Regulations 1999 carry the same safety model. Regulation 6 requires the family name, forenames, gender, nationality and date of birth of each person on board. It lets passengers volunteer special care needs and an emergency contact number 9.
The information must be collected before the ship leaves the landing point and reported to the National Single Window within 15 minutes of departure. A transitional rule allowed reporting to the company's passenger registrar instead until 20 December 2025 9.
For border purposes, the Immigration and Police (Passenger, Crew and Service Information) Order 2008 applies to ships as well as aircraft. An immigration officer may require a passenger list showing names and nationality or citizenship. The Order lists ship name and nationality of ship among voyage details 10.
How long sea passenger data is kept
| Rule | Retention stated |
|---|---|
| EU Directive 98/41/EC, company data 5 | Kept no longer than necessary, and only until the voyage is safely completed, then erased automatically 5 |
| EU Directive 98/41/EC, use limit 5 | Data may not be processed or used for any other purpose 5 |
| US APIS 8 | No more than 12 months from collection in APIS. Copies sent to other systems follow those systems' periods 8 |
Common questions
Do ferry passengers have to give their date of birth?
In the EU and UK, yes, on voyages covered by the registration rules. Directive 98/41/EC lists date of birth for departures where the next port is more than 20 miles away 5,9.
Do cruise passengers to the US go through APIS?
Yes. Commercial vessel operators send an electronic arrival manifest to CBP under 19 CFR 4.7b. The APIS notice covers air and vessel carriers 6,8.
Are ferries exempt from US manifest rules?
Yes. 19 CFR 4.7b and 4.64 do not require a passenger manifest from a vessel operating as a ferry 6,7.
Rules and fees change. Check the official site linked above before you apply or pay. Spotted an error? Email [email protected] with the official link.
Sources
- IMO: Facilitation (FAL), the free flow of trade by ship
- legislation.gov.uk: Directive 2010/65/EU, Annex, list of reporting formalities
- legislation.gov.uk: Directive 2010/65/EU of 20 October 2010, Article 5, electronic transmission of data
- legislation.gov.uk: Regulation (EU) 2019/1239 of 20 June 2019, Articles 25 and 26
- legislation.gov.uk: Directive (EU) 2017/2109 amending Council Directive 98/41/EC (15 November 2017)
- Cornell LII: 19 CFR 4.7b, electronic passenger and crew arrival manifests
- Cornell LII: 19 CFR 4.64, electronic passenger and crew member departure manifests
- Federal Register: DHS/CBP-005 Advance Passenger Information System, system of records notice (13 March 2015)
- legislation.gov.uk: SI 1999/1869, Merchant Shipping (Counting and Registration of Persons on Board Passenger Ships) Regulations 1999, regulation 6
- legislation.gov.uk: SI 2008/5, Immigration and Police (Passenger, Crew and Service Information) Order 2008
Related
- Advance Passenger Information (API) explained
What API data is, which fields airlines send, who receives it, the legal basis, how long it is kept, and examples from four jurisdictions.
- Passenger data retention
How long governments keep PNR, API and biometric records about air travellers, what must be masked or deleted, and what the EU Court of Justice ruled.
- US passenger data rules: APIS, Secure Flight and ATS
How CBP's APIS, TSA's Secure Flight and the Automated Targeting System collect air passenger data, the legal basis, retention periods and audit findings.
- UK passenger data rules: API, PNR, Border Force and the ETA
The UK law on passenger and crew information, the data carriers send, Home Office retention periods, the ETA, ICO complaints and inspection findings.
- Children's data at borders: API fields, biometrics and consent letters
How border systems record data on minors: API and PNR fields, fingerprint and face age limits in the EU, US and UK, eGate ages and consent letters.