Passenger data retention

Last checked: 21 October 2026 · How passenger data works

Passenger data retention is the period a government keeps records about a traveller before it must delete or mask them ¹. Under the EU PNR Directive, a Passenger Information Unit keeps PNR data for five years and masks identifying fields after six months ¹. In June 2022 the EU Court of Justice ruled that a general five-year period for all passengers is not compatible with EU law ². Periods for biometric border records differ by system and country ^3,4.

EU PNR retention: Five years after transfer to the Passenger Information Unit ¹
EU PNR masking: After six months ¹
Court ruling: Case C-817/19, 21 June 2022 ²
EU Entry/Exit System: Three years, or five years for overstayers ³
US citizen face photos: No more than 12 hours ⁴

What the EU PNR Directive sets

Directive (EU) 2016/681 says PNR data that airlines send to a Passenger Information Unit (PIU) are kept in a database for five years after transfer ¹. The period applies in the Member State where the flight lands or departs ¹.

After six months, all PNR data must be depersonalised by masking out fields that could identify the passenger directly ¹. The masked fields are listed below ¹.

Names, including other passengers on the same booking and the number travelling together ¹
Address and contact information ¹
All forms of payment information, including billing address ¹
Frequent flyer information ¹
General remarks that could identify the passenger directly ¹
Any API data collected ¹

Unmasking and deletion

After six months, the full PNR record may be disclosed only where it is reasonably believed necessary for the Directive's purposes and a judicial authority or another competent national authority approves ¹. The PIU data protection officer must be informed and carries out an ex-post review ¹.

At the end of five years the data must be deleted permanently ¹. Data already passed to a competent authority for a specific case fall under national law for retention ¹.

The EU Court of Justice ruling

On 21 June 2022 the Court of Justice ruled in Case C-817/19, Ligue des droits humains ². It held that EU law precludes national legislation providing a general retention period of five years for PNR data ².

The Court said that after the initial six months, keeping the data of passengers for whom there is no objective evidence of risk does not appear limited to what is strictly necessary ². The same ruling said a PIU may not use self-learning artificial intelligence systems for the advance assessment of PNR data ².

Biometric and border crossing records

Record	Retention	Source
EU Entry/Exit System, traveller who respected the authorised stay ³	Three years ³	Regulation (EU) 2017/2226 ³
EU Entry/Exit System, traveller who overstayed ³	Five years, then automatic erasure ³	Regulation (EU) 2017/2226 ³
EU Entry/Exit System, certain family members of EU citizens ³	Up to one year after exit ³	Regulation (EU) 2017/2226 ³
US CBP face photo of a US citizen ⁴	No more than 12 hours after identity verification ⁴	CBP biometric privacy policy ⁴

National data protection laws

The Philippine Data Privacy Act of 2012 says personal information is kept only as long as necessary for the purpose it was obtained ⁵. It permits longer retention to establish or defend legal claims, for legitimate business purposes, or as provided by law ⁵.

Kenya's Data Protection Act 2019 contains section 39, headed Limitation to retention of personal data ⁶. Neither law sets a fixed period for passenger records ^5,6.

Logs have their own retention

Records of who used PNR data are kept separately. The PNR Directive requires PIU logs of collection, consultation, disclosure and erasure to be kept for five years ¹. See the page on access logging and audit trails.

Common questions

How long does the EU keep PNR data?

The PNR Directive sets five years from transfer, with identifying fields masked after six months ¹. The Court of Justice ruled in June 2022 that a general five-year period for all passengers is precluded by EU law ².

Can masked PNR data be unmasked?

Yes, after approval by a judicial authority or another competent national authority, with the PIU data protection officer informed ¹.

How long does the EU keep border crossing records?

The Entry/Exit System keeps them for three years, or five years for people who overstayed ³.

Does the Philippines set a retention period for passenger data?

The Data Privacy Act of 2012 says data are kept only as long as necessary for their purpose, or as provided by law ⁵.

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

Passenger Name Record (PNR) data explained
What PNR data is, the 19 EU data elements, who sends and receives it, the legal basis, retention rules and the 2022 EU Court of Justice ruling.
The EU PNR Directive (Directive (EU) 2016/681)
What the EU PNR Directive requires of airlines and Member States, the 19 data elements it covers, retention rules, and what the EU Court of Justice ruled.
Access logging and audit trails
What access logs for passenger data must record, how long logs are kept, who may read them, and what an audit found when controls failed.
Biometric data at borders
Which fingerprints and facial images border agencies collect from travellers, the legal basis, who holds the records and how long they are kept.
Passenger Information Units
What a Passenger Information Unit does with API and PNR data, the EU rules that govern it, the limits set by the EU Court of Justice, and examples.
EU Entry/Exit System (EES) and ETIAS: data, dates and oversight
What the EU Entry/Exit System and ETIAS collect, official start dates, how long data is kept, eu-LISA's role and EDPS supervision.