Immigration Bill

Written evidence from Qantas (IB 58)

Proposed changes to the Immigration Bill


Qantas is grateful for the opportunity to comment on the proposed changes to the Immigration Bill in relation to Embarkation Checks which was introduced into the House of Commons on 10 October 2013.

Qantas is an Australian public company, listed on the Australian Stock Exchange. Qantas has operated as a regular passenger airline for over 90 years. The company’s main business is the transportation of passengers and airfreight.

The UK is one of the countries served by Qantas. In addition to numerous codeshare flights, Qantas directly operates 14 services per week to and from the UK.

While Qantas welcomes the opportunity to work with the Home Office in relation to its commitment to develop an efficient system of exit checks that does not compromise border security or unnecessarily disrupt passenger traffic, we are particularly concerned about one of the proposed changes to the Immigration Bill in relation to Embarkation Checks (Clause 5B of Schedule 7).

These provisions introduce the ability for the Secretary of State to direct carriers or port operators to make arrangements for designated persons to exercise the power of examination in respect of embarking passengers. The Bill also provides that a failure by a carrier or port operator to comply with a direction without reasonable excuse will be an offence under the relevant section.

Qantas has concerns with proposed changes to the legislation that could require carriers to perform specified exit immigration activities on behalf of the UK Government. Border control is a government function which forms part of a broader national security agenda and we do not believe it is appropriate for any activity currently performed by an immigration officer, even to augment technological capability, to be delegated to carriers. By delegating this function to a number of different entities, such as carriers, the UK Government will create inconsistencies in the manner in which the functions are carried out. Each entity would approach the function differently which will lead to inaccuracies and inconsistencies in the data produced and create greater potential for the system to be subverted or defrauded. In addition, the UK Government will not have a single body of expert technicians who are trained and experienced in the tasks involved. Given the nature of those tasks, there is a great benefit to be gained from that experience and knowledge that goes beyond the mere ability to discharge of a statutory obligation. It is also likely that the management of the resources necessary to deliver exit immigration activities will be more efficient and therefore cheaper for the travelling public, where all the staff are managed by a single service provider. This will better allow for allocation of resources across the highly dynamic demands of the passenger volumes of individual airlines, by pooling and therefore smoothing that demand.

Notwithstanding this, Qantas is committed to supporting the UK Government’s border security needs through the provision of the required data from check-in and our own reservation and departure control systems. In this regard, we have invested considerably in the development of new requirements and systems such as pre-departure checks and passenger name records (PNR) to improve data quality.

Qantas understands the Home Office’s commitment to introducing exit checks by 2015 and we look forward to working together to improve the efficiency of this process.

November 2013

Prepared 20th November 2013