EU-Switzerland PNR Agreement 2026: obligations for airlines with routes to Switzerland

Key data

Airlines with routes between the European Union and Switzerland have a new compliance obligation: to transmit PNR (Passenger Name Record) data of their passengers to Swiss authorities. This is established by Council Decision (EU) 2026/643, of 23 February 2026, which authorizes the signature of the bilateral agreement between the EU and the Swiss Confederation for the transfer of this data.

The agreement is not a conceptual novelty in Europe — the EU already has PNR agreements with countries such as the United States, Australia or Canada — but it does represent a new and direct operational obligation for all air carriers operating on this route.

What does this regulation establish?

The agreement regulates the transfer of Passenger Name Record (PNR) data from airlines to Swiss law enforcement authorities. Its purpose is to enable Switzerland to use that information to prevent, detect, investigate and prosecute terrorism offences and serious crimes.

The PNR data that must be transmitted includes information collected at the time of booking and boarding. According to the agreement, this data includes:

• Passenger name
• Flight itinerary
• Baggage data
• Payment method

The agreement is not limited to data exchange: it also establishes a framework of data protection guarantees and sets explicit use limitations. The PNR data transferred may only be used for the purposes provided for in the agreement — terrorism and serious crimes — and not for other purposes.

From an institutional perspective, Decision 2026/643 authorizes the signature of the agreement on behalf of the EU and strengthens bilateral judicial and police cooperation between the European Union and Switzerland.

Economic and operational impact

For airlines, the impact is mainly operational and compliance-related. No specific fees or economic sanctions are established in the published signature decision, but the data transmission obligations entail real costs at several levels:

• Technological adaptation: Reservation management systems and PNR data transmission systems must be configured to send information to the competent Swiss authorities, similar to how this is already done with other countries with existing PNR agreements.
• Data protection compliance: Airlines must ensure that transmission is carried out within the framework of guarantees established in the agreement, which may require review of privacy policies, contracts with reservation system providers and internal procedures.
• Coordination with authorities: It will be necessary to identify which Swiss authorities are the competent recipients of the data and establish appropriate transmission channels.

For air travelers, the impact is indirect: their booking data will be shared with Swiss authorities when they fly on EU-Switzerland routes, within the framework of the agreement's guarantees.

Who does it affect?

• Airlines with routes between the EU and Switzerland: They are the main obligated parties. They must transmit PNR data of their passengers to the competent Swiss authorities.
• Air transport operators that manage flights on the EU-Switzerland corridor, regardless of their country of origin.
• Compliance and data protection departments of the affected airlines, which must adapt processes and systems.
• Global Distribution System (GDS) providers that manage PNR data on behalf of airlines.
• Law enforcement and judicial authorities of the EU Member States and Switzerland, which benefit from the strengthened cooperation framework.
• Air travelers on EU-Switzerland routes, whose booking data are subject to this transfer regime.

Practical example

A Spanish airline operates daily flights between Madrid and Zurich. Upon entry into force of the agreement, this company will be obliged to transmit to the competent Swiss authorities the PNR data of each passenger on those routes.

For a passenger booking that flight, the transmitted data will include their full name, flight itinerary (Madrid-Zurich, date and time), information about their checked baggage and the payment method used in the booking.

The airline must have an operational data transmission system to Swiss authorities before the agreement enters into force. If it already has PNR systems configured for other countries with similar agreements (such as the US or Australia), the technical adaptation will be simpler, although it will require configuring the specific channel for Switzerland and verifying that it complies with the data protection guarantees of the new agreement.

What should companies do now?

1. Identify if you operate EU-Switzerland routes: If your airline or operator has flights between any EU Member State and Switzerland, this regulation directly affects you.
2. Review existing PNR transmission systems: Check whether your current systems can be configured to transmit data to Swiss authorities, leveraging integrations already in place with other countries with PNR agreements.
3. Identify the recipient Swiss authorities: Once the full text of the agreement is published, determine which Swiss authorities are designated as competent to receive PNR data.
4. Update privacy and data protection policies: Inform passengers about the transfer of their PNR data to Switzerland, in compliance with the transparency obligations of the GDPR and the agreement itself.
5. Review contracts with GDS providers: If you use a Global Distribution System (GDS) to manage reservations, verify that the provider can assume the PNR transmission obligations to Switzerland.
6. Monitor the entry into force date: The date of application of the agreement has not been specified yet. Keep track of official publications in the EU Official Journal to find out when compliance will be required.