USA flights: New APIS transmission rules on gender codes and U.S. passport number formats

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.

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 may affect international air operators carrying trans, nonbinary, and intersex individuals to the U.S. from countries that recognize additional gender markers on official travel documents. These markers often include "X” or “U”.

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 system update for interactive submissions, 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.

It remains unclear whether passengers with non-binary or third-gender markers in their passports will be able to travel to the USA. Although the U.S. Bureau of Consular Affairs currently states on their website that passports with “X” gender markers remain valid for entry into the United States, the new APIS transmissions will not support gender codes outside of “M” or “F.”

Unsupported gender markers: Operational risk for air operators

Air operators may find themselves in a difficult position since:

• In the transmission process, they are required to match the data exactly as it appears on the passport.
• The interactive system will reject data containing unsupported gender markers.
• There is currently no official guidance from CBP on how to handle this conflict for non-interactive (batch) submissions.

The PnrGo team has reached out to CBP for further clarification. In the meantime, we strongly advise operators to contact CBP directly if unsure about how to proceed.

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.

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.

System Enhancements:

• Operators will now receive automatic warnings from PnrGo if an unsupported gender marker or invalid passport format is detected before transmission.
• The PnrGo system will NOT block the data transfers with ‘unsupported’ gender markers and ‘old’ U.S. passport numbers (note that the U.S. interactive system will return the ‘X’ response). Operators are advised to consult CBP to confirm whether they can bring such passengers to the U.S. border.

New warning messages have been activated in the PnrGo system, following the recent changes in the APIS transmissions in the U.S.

This proactive check helps to prevent operational disruptions.

Should you have any questions, feel free to reach out to our team.