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Amy Wilder

Operators flying to Hong Kong will be required to submit Advance Passenger Information (API) for all crew and passengers on inbound flights beginning April 29, according to <a href="https://www.hkbac.com/common/pdf/Mandate%20Letter%20%28Implementation%29_HKBAC.pdf">a letter from the Hong Kong Immigration Department</a> to the Hong Kong Business Aviation Centre (HKBAC). While the system will be active this month, full enforcement of the API submission requirement will begin September 1 after a transitional period.
API submissions will be mandatory for both private and commercial business aviation flights and must include data for all travelers, including crew and transit passengers. The requirement stems from a new system implemented by the Hong Kong Immigration Department and is designed to improve security and processing efficiency.
Operators will need to register and submit API information themselves via an <a href="https://apis.immd.gov.hk/login?redirect=%2Findex">online portal</a>. The HKBAC FBO confirmed that it cannot complete the filings on behalf of clients, although it can assist with account setup.
An explainer published by aviation risk management organization <a href="https://ops.group/blog/hong-kong-apis/">OpsGroup outlines several operational considerations,</a> noting that “operators must submit passenger data no later than 40 minutes prior to departure, and crew data at least 60 minutes prior.” In addition, OpsGroup reported that operators are required to submit crew information twice—once before departure and again following takeoff in a “Flight Close-out Message”—even if there are no changes in crew composition.
The Immigration system also includes a “No Board” function. “If the APIS system returns a ‘No Board’ message for any traveller, including crew members, they are not permitted to board the flight,” OpsGroup explained, citing guidance provided to its members. Operators may contact the Command Centre directly for clarification if necessary.
Additionally, the pilot group shared practical observations from a recent flight to VHHH/Hong Kong International Airport, reporting that “all operations center around HKBAC,” which coordinates parking and slot management for business aviation traffic. Pilots noted that Hong Kong remains a “high-load, high-procedure” airport with considerable mechanical turbulence on arrival due to the surrounding terrain and significant lead times for slot and permit approvals.
The new API requirement adds another layer to the sequence of operational permissions needed to access Hong Kong by business aircraft, which already includes individual applications for landing permits, parking, slots, and ground handling. OpsGroup recommended that operators apply for these in the following order: landing permit, parking, ground handling, slots, and finally API.
While the rule enters into effect on April 29, the Hong Kong authorities will not enforce penalties during the transitional period that ends September 1. However, inaccurate or incomplete submissions may be subject to fines after that. Additional guidance on the new API system is available via the Immigration Department’s submission website.

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