Face Scans for Boarding: CBP Test Lives On!
Published Date: 3/4/2025
Notice
Summary
U.S. Customs and Border Protection is renewing a cool test that helps airlines and ships quickly check traveler identities using facial comparison tech. This test, which started in 2023, lets carriers speed up the boarding process by making sure passenger info is spot-on before departure. The test will run for two more years, until February 16, 2027, and is free for carriers who want to join.
Analyzed Economic Effects
7 provisions identified: 4 benefits, 2 costs, 1 mixed.
Carriers Must Buy Capture Equipment ($5,000–$20,000/gate)
CBP will provide participating carriers access to its TVS free for the test, but carriers are responsible for selecting and purchasing image capture and transmission equipment. CBP estimates equipment costs of about $5,000 to $20,000 per departure gate based on initial testing experience.
TVS Match Can Replace Manual ID Checks
If you operate a participating commercial air or sea carrier and CBP's Traveler Verification Service (TVS) matches a traveler's facial image to CBP's gallery, your APIS verification requirements under 19 CFR 122.49a(d), 122.49b(d), 122.75a(d), and 122.75b(d) are considered fulfilled and you are not required to perform additional manual identity or manifest verification. Carriers still must ensure travelers have valid passports or authorized travel documents.
Photo Retention: Immediate Deletion for U.S. Citizens; Long Retention for Some Aliens
CBP will delete photos of U.S. citizens immediately upon confirmation of U.S. citizenship (though photos may sit in an inaccessible queue up to 12 hours in some situations). Photos of aliens and no-matches may be retained up to 14 days in the Automated Targeting System (ATS), and DHS may retain facial images of in-scope aliens for up to 75 years in the IDENT system.
Carriers Must Not Retain Photos and Face Sanctions for Misconduct
Participating carriers must agree not to store or retain any photos taken while using TVS, provide a CBP-approved auditing method, and ensure system log files meet CBP approval. Carriers that fail to comply may be suspended from the test and subject to penalties, liquidated damages, or other administrative or judicial sanctions under APIS regulations.
Test Extended Through February 16, 2027
CBP renewed the Facial Comparison for APIS Compliance Test for two more years, beginning on February 16, 2025 and ending on February 16, 2027. The initial voluntary test began on February 16, 2023, and CBP may modify or discontinue the test or refuse carrier participation.
Travelers Can Opt Out of Facial Comparison
You may opt out of the APIS facial comparison procedure by notifying the carrier. Carriers must post clear and visible signs (and may give verbal announcements) explaining opt-out; if you opt out the carrier must perform a manual review of travel documents to meet APIS requirements.
CBP Monitoring Finds No Measurable Demographic Bias
CBP will evaluate test results including the percentage of travelers with gallery photos and matching accuracy across demographic factors. CBP states its operational data continues to show no measurable differential matching performance based on demographic factors and will continue monitoring and working with NIST and partners.
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