EBAA has received updates on the PNR issue in Poland from the team at Polish law firm Wardynski. After pushback from EBAA and other aviation associations, the Polish government put a moratorium on violations of PNR reporting that took place in Poland prior to the 4th of February 2022. EBAA has been informed that this moratorium has now expired.

After the 5th of February 2024, all pending investigations by the Border Guard will be resumed, and any violations that were not subject to proceedings before may be prosecuted in new investigations.

At the moment, there are no publicly announced government plans to prolong the moratorium or implement other solutions. While this option remains a possibility in the future, for the time being, EBAA Members should assume that any PRN violations concerning flights prior to the 4th of February 2022 will likely be prosecuted by the Polish Border Guard.

As a consequence, EBAA Members should be on high alert for any correspondence (both by post and email) coming from Polish authorities, especially if they have not engaged local legal counsel before. Obtaining legal advice before responding to any query from the Polish authorities like the Border Guard is highly advised, as any and all information willingly provided by the operator can be used against them in the administrative penalty proceedings concerning PNR violations.

Below you will find the contact details for law firms in Poland that have been dealing with PNR issues so far.

EBAA members & lawyers:

• Paweł Mazur Wardynski & Partners
• Michał Dudkowiak Dudkowiak & Partners
• Jadwiga Stryczyńska WKB Lawyers
• Martyna Ryś-Wilgus PETERKA & PARTNERS
• Beata Składanek-Wikieł PETERKA & PARTNERS
• Michał Jaworski JMK Legal

Other lawyers

• Jolanta Dabrowicz DLA Piper
• Anna Burchacińska-Mańko MMM Legal

Please note EBAA has no links with any of these law firms. If you are aware of any other law firms working on this issue please let us know and we will add them to this list.

Should you require PNR support for flights to Poland or other EU countries please be aware of the special offer that PNR specialist PnrGo has created for EBAA members.