The U.S. Customs and Border Protection (CBP) has announced upcoming changes to Advance Passenger Information System (APIS) transmissions, impacting how air operators submit gender data and validate U.S. passport numbers. These updates have legal, technical, and operational implications for air operators transporting passengers to the United States.
As part of the pre-departure process, air operators are required to report traveler’s passport information, including gender and passport number.
APIS transmission updates at a glanceKey changes:
Scope:
Effective dates:
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Gender markers in passports: What air operators should know
There is a lot of controversy surrounding Donald Trump’s executive order on “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government”. Declared on 20th January 2025, the order states that the U.S. recognizes only two sexes, male (M) and female (F).
The new policy and its practical implications have raised concerns among air operators carrying trans, nonbinary, and intersex individuals. Some countries use additional gender markers—such as “X” or “U”—on official travel documents. Analogically, US passports issued prior to the executive order may still contain the “X” gender marker and, according to the U.S. Bureau of Consular Affairs, they remain valid.
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UPDATED 23.10.2025: PnrGo has managed to confirm with the U.S. Customs and Border Protection office that air carriers operating international flights (to and from the USA) will not experience problems if they follow instructions issued in the CBP Bulletin on 7 July 2025—even if this information was not repeated in the later edition of the bulletin, sent out by email on 23 September 2025. |
How the new U.S. gender policy affects APIS submissions
The API data submission systems in the U.S. are managed by the Customs and Border Protection (CBP) agency. Air operators are normally required to use one of the following data transfer methods:
- Interactive submissions: Real-time data with instant validation feedback.
- Non-interactive (batch) submissions: Data is submitted in bulk without feedback.
Following the announced system updates, operators will receive an X response (=Insufficient Information) and a request for resubmission if any characters other than "M" or "F" are entered in the gender input field. This change will be effective on 14th October 2025.
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UPDATED 23.10.2025: PnrGo received a confirmation from the CBP APIS Program Manager that the guideline published in the July edition of the CBP Bulletin is still valid: Additionally, CBP has clarified that these new guidelines concern both interactive and non-interactive submissions. For the latter, carriers need to verify the response through the eAPIS portal. |
APIS document validation: New U.S. passport number format
Starting on 6th October 2025, CBP is also implementing stricter validation for U.S. passport numbers. Below are the new format requirements to successfully pass document validation in the APIS transmission process:
Option 1: Numeric format
- Nine numeric digits
- Must have a numerical value of 4XXXXXXXX or higher
Option 2: Alpha-numeric format
- Nine characters total
- First character must be A, X, Y, or Z:
- “A” for Regular passport
- "X" for Diplomatic passports
- "Y" for Official passports
- "Z" for Service passports
- Followed by exactly eight numeric digits
Invalid number format: X response
Any U.S.-issued passports that do not match the new format requirements will also result in the ‘X’ system response from CBP, requiring a resubmission. This may create problems for U.S. passport holders using documents with the old number format, and for air operators who need to transmit the correct information.
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UPDATED 20.10.2025: CBP has clarified that the changes in the APIS submission process apply to all carriers, and concern both interactive and non-interactive submissions. This means that for non-interactive submissions, carriers will need to manually check these responses through the eAPIS portal. |
PnrGo system for air operators: APIS transmissions update
PnrGo continues to support air operators with passenger and crew data transfers to the U.S., including APIS transmissions and TSA Secure Flight checks.
Operators will now receive automatic warnings from PnrGo if an unsupported gender marker or invalid passport format is detected before transmission. This proactive check helps to prevent operational disruptions.
Should you have any questions, feel free to reach out to our team.
