U.S. Customs and Border Protection (CBP) has issued updates to the Advance Passenger Information System (APIS) requirements that may affect business travelers and airlines. These changes, implemented in response to Executive Order 14168, "Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government" issued in January 2025, introduce enhanced validation requirements for passenger data submitted by commercial air carriers.
Key Changes Overview
Sex Field Requirements: Effective Oct. 14, 2025, CBP systems will only accept "M" (Male) or "F" (Female) in the sex field of APIS transmissions. Any other characters will result in an "X Response-Insufficient Information" error, requiring airlines to resubmit the passenger data with corrected information.
U.S. Passport Format Validation: Starting Oct. 6, 2025, CBP will implement stricter validation for U.S. passport numbers transmitted through APIS.
Implementation Timeline
- Sept. 17, 2025: Testing environment (EDU) available for sex field validation changes.
- Sept. 24, 2025: Testing environment available for U.S. passport format validation.
- Oct. 6, 2025: U.S. passport format validation goes live in production.
- Oct. 14, 2025: Sex field validation goes live in production.
U.S. Passport Number Format Requirements
Valid U.S. passport numbers must follow one of these formats:
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
- Followed by exactly eight numeric digits
The leading alpha characters indicate passport type:
- A: Regular passport
- X: Diplomatic passport
- Y: Official passport
- Z: Service passport
Impact on Business Travel
Employer Considerations:
- Review travel policies and booking procedures with travel management companies;
- Ensure corporate travel booking systems capture accurate passenger information;
- Brief frequent business travelers on the importance of providing exact passport details; and
- Consider potential delays if incorrect information requires resubmission.
Employees Considerations:
- Double-check that passport information matches exactly what is on the physical document when booking travel;
- Verify that airlines have the correct sex designation as listed on the passport;
- Allow additional time for potential rebooking if passenger information errors occur; and
- Ensure the U.S. passport number format is valid if traveling on a U.S. passport.
Carrier Responsibilities
Airlines remain responsible for comparing travel documents passengers present with the information transmitted to CBP. Airline carriers must ensure accuracy in all APIS data submissions, including traveler sex designation and passport number formatting.
Practical Considerations
- Document Verification: Provide passport information exactly as it appears on travel documents.
- Sex Designation Accuracy: Ensure the sex designation transmitted to CBP matches exactly what appears on passports, regardless of personal identification.
- Passport Updates: Consider whether passport updates may be necessary to ensure smooth travel.
- Early Booking: Complete travel bookings in advance to allow time for any necessary corrections.
- Travel Management: Work with experienced travel agencies familiar with APIS requirements.
- Communication: Ensure clear communication between travelers, booking agents, and airlines regarding exact document details.
Special Considerations
Document Inconsistencies: If travelers' passports contains a sex designation that differs from their current identification, airlines must still transmit the information exactly as it appears on their passport documents. CBP systems will only accept the "M" or "F" designation that matches travel documents.
Non-Binary Passport Designations: Passports issued with "X" or other non-binary markers will be rejected by CBP systems, requiring resubmission with valid documentation showing "M" or "F" designation.
Passport Updates: Travelers experiencing documentation inconsistencies may wish to consult with the relevant passport issuing authority about available options for updating travel documents.
Takeaways
The implementation of these changes may cause initial adjustment periods. Business travelers and employers should work closely with their travel management companies to enhance compliance with these new requirements. Providing accurate and complete travel documentation remains essential for efficient international travel.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
