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Hold Baggage Reconciliation (2025)

Executive Summary
In June 2025, ICAO released updated guidance on Hold Baggage Screening, Handling, and Processing,
specifically clarifying procedures for accompanied versus unaccompanied baggage. This update aligns Annex
17 interpretation with existing standards, enabling risk-based security measures that improve throughput,
operational efficiency, and economic sustainability. A public LinkedIn message, then an official ICAO Electronic
Bulletin (EB 2025/26) has been released on 28 July and 5 August 2025 respectively.

The new guidance allows unaccompanied hold baggage—previously screened to a defined high standard
using advanced methodologies - to remain onboard without mandatory offloading, supporting the wider
adoption of One-Stop Security (OSS) and Recognition of Equivalence (RoE) agreements, particularly at
major hubs equipped with advanced screening technologies.

Aircraft operators are now encouraged to partner with national regulators by submitting data-driven risk
assessments, proposing pilot programs, sharing operational performance metrics, and co-developing
performance-based security protocols to gain approval for risk-based hold baggage offload procedures.

This development addresses a long-standing misalignment wherein ICAO’s Aviation Security Manual (Doc 8973)
and Universal Security Audit Program protocol questions implied automatic offloading was necessary, despite
Annex 17’s 2011 revision removing this requirement. The outdated interpretation had caused unnecessary re-
screening, operational inefficiencies, and hindered international agreements like OSS and RoE.

IATA has played a pivotal role since 2020 in leading industry advocacy through working papers, position
statements, and detailed analysis challenging the outdated guidance. This advocacy has been instrumental in
aligning ICAO guidance with evolving international standards and technological advancements, supporting
ICAO’s broader mandate under Article 44 of the Chicago Convention to promote safe, efficient, and economically
sustainable international air transport.

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Legal and Technical Background

The foundational aims and objectives of ICAO, as outlined in Article 44 of the Chicago Convention, include not
only the development of principles and techniques to enhance safety and security, but also the regular, efficient
and economically sustainable development of international air transport. These goals can only be effectively
advanced through the recognition and proper consideration of industry’s proposals in relevant ICAO bodies. This
is especially critical when advocating for the continuous updating of ICAO Annex 17 and associated guidance
materials to address implementation challenges identified by both operators and regulators.

A clear example on the need for better alignment between Annex 17 and its associated guidance material
ensuring internationally harmonized implementation, is the question of Hold Baggage (HB) Reconciliation (HBR).

In many States, national regulations still reference an outdated version of Annex 17 “Standard 4.5.3”, introduced
in 2006. This standard required commercial air transport operators to not transport the HB of passengers who
are not on board the aircraft unless that baggage is identified as unaccompanied and subjected to additional
screening. The requirement for “additional” screening created an operational synchronous obligation to offload
any HB newly identified as unaccompanied for performing additional screening. At the point of origin, this meant
re-screening using the same detection technology. At transfer points, it required new screening regardless of
existing One-Stop Security (OSS) or Recognition of Equivalence (RoE) arrangements.

Given the deployment of advanced detection technologies at points of origins, the actual benefit of “additional
screening” on the level of security is debatable. However, the negative impacts on operational regularity,
efficiency and economical sustainability were evident, especially considering the cascading effects caused by
upstream delays at different transfer points. Interestingly, similar but non-synchronous security requirements
already existed in Standard 4.5.5 (now 4.5.6) together with the acceptance for carriage by the airline and the
traceability, or operational reconciliation of all HB (accompanied and unaccompanied), dating back to 2006.

Since 2011, Standard 4.5.3 has been revised replacing the term “passengers” by “persons” and more importantly
“additional” by “appropriate” screening, meaning that the automatic offloading of unaccompanied HB for
performing additional screening was no longer an international requirement under Annex 17.

However, the associated guidance contained in the ICAO Aviation Security Manual (Doc 8973, Restricted)
continued to reflect an outdated interpretation with an automatic offloading of HB when its owner failed to board.
This misalignment exists with some USAP-CMA Protocol Questions 1 still outdated.

IATA challenged that outdated interpretation which was hindering potential Innovation in Security such as 100%
Hold Baggage Screening One-Stop Security Initiative (100% HBS OSS)2 and requested an urgent update of ICAO
guidance via one ICAO AVSEC Panel Working Paper (2023) questioning the need to offload appropriately
identified and screened hold baggage 2. In addition, IATA published public position papers on Hold Baggage (HB)
Security Procedures (2024) and Hold Baggage (HB) Security (2025) as well as related content in the IATA Annual
Security Report (2023) and IATA Annual Security Report (2024).

All these advocacy efforts proved successful, culminating in ICAO’s release of new guidance material
on Hold Baggage Screening, Handling and Processing in June 2025 3, in particular a section dedicated
to “Hold Baggage Reconciliation – the accompanied versus unaccompanied process” .
An official ICAO Electronic Bulletin (EB 2025/26) has been released on 5 August 2025.

1
USAP-CMA PQ 6.215 (2025) mentions ‘[…] retrieving and offloading baggage […] if a person with baggage does not board […]”
2
request access to the SeMS Aviation Community in contacting [email protected]
3
(ICAO secure portal) - https://portal.icao.int/icao-net/Other%20ICAO%20publications/Hold_Baggage_Screening_Handling_and_Processing.EN.pdf

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New ICAO Hold Baggage Guidance Material (June 2025)

Aircraft and airport operators should contact their respective
appropriate authorities to obtain a copy of the new ICAO guidance
material, which is made available to States via the ICAO secure portal3.

In the meantime, operators could retrieve all technical information in two

IATA position papers already available Hold Baggage (HB) Security
Procedures (2024) and Hold Baggage (HB) Security (2025) that are totally
aligned with the newly developed guidance material reflected in the ICAO
Aviation Security Manual (Doc 8973, June 2025). This is worth mentioning
the IATA concept of UNAR introduced in the PSCRM Edition 40 (2020),
currently in the Recommended Practice 1745a) in PSCRM Edition 42 (2022),
which allows the secure acceptance of HB in different flight (as for
Unaccompanied Baggage - UNAC or RUSH bags) but ahead of its owner
board an aircraft.

In addition, IATA launched a 10-year Global Baggage Roadmap to modernize baggage operations, built around
three pillars: baggage Information Exchange and Data Standardization, Baggage Tracking and Automation, and
Streamlining the baggage claim process, combatting fraud, and enhancing the customer experience. Please visit
the IATA Baggage Operations website for more information.

Acceptance Principles for Hold Baggage (2025)

In 2025, the following principles shall apply for all HB engaged in commercial air transport operations:
1. be accepted only from passengers who have checking in for a flight, or from a crew on duty,
2. be accepted by a responsible agent or authorized representative of the aircraft operator, who should verify
the identity of the person checking the HB. Along with a valid boarding pass (or crew ID),
3. only be loaded onto an aircraft when it has been screened at their point of origin using security systems
and appropriate standards capable of detecting the presence of explosives and explosive devices with
standard of screening defined by authorities,
4. be protected from unauthorized interference from the point of screening (or acceptance into the care of
the airline) until departure of the aircraft in security restricted areas,
5. be rescreened if the integrity of the protection is jeopardized,
6. be identified as accompanied or unaccompanied depending on the presence of their owner on board

Unaccompanied Hold Baggage Reconciliation (HBR)

7. When the owner of the HB is not on board the aircraft, States may consider accepting the implementation
of the following measures to a newly becoming unaccompanied HB:
a. require that any HB that becomes unaccompanied should be offloaded. However, exceptions may be
made when factors that are clearly beyond the owner’s control led to the HB becoming
unaccompanied, and/or
b. permit exceptions where the HB has already been screened to a defined high standard before it
became unaccompanied (for example using the most advanced and effective screening
methodology), and/or
c. allow virtual rescreening via the review of the original screening image by a screener, considering the
additional risk inherent in an HB becoming unaccompanied,
8. All decisions should be based on an operational risk assessment conducted by the aircraft operator,

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9. When HB is properly (re)identified and screened to the appropriate standard as determined by the
authorities, it could be accepted (or not) for carriage by the aircraft operator, and
10. If accepted for carriage, HB must be operationally tracked (on the ground and during the journey) with the
ultimate operational objective of reconciling them with their respective owners in the end of the journey.

Operational Risk Assessment for Unaccompanied Hold Baggage

As stated in ICAO Annex 17 Standard 4.5.6 (2022, same wording since 2006) which serves as the primary
reference in IATA documents, all appropriately screened and identified HB must be accepted for carriage by the
air carrier, or aircraft operator.
4.5.6 Each Contracting State shall ensure that commercial air transport operators only transport items of hold
baggage which have been individually identified as accompanied or unaccompanied, screened to the appropriate standard
and accepted for carriage on that flight by the air carrier. All such baggage should be recorded as meeting these criteria and
authorized for carriage on that flight.
Furthermore, as outlined in the latest ICAO guidance material for Hold Baggage (HB) and Hold Baggage
Reconciliation (HBR), all decisions related to the security controls applied to HB that becomes newly
unaccompanied HB should be based on both the results of national risk assessment conducted by the
authorities 4 and operational risk assessment performed by the aircraft operator 5.

To support aircraft operators, and their External Service Providers (ESPs) implementing HB security measures
on the operators’ behalf, IATA has developed a harmonized checklist. This checklist covers all steps from the
acceptance of the hold baggage to the operational considerations for offloading decisions, based on the
operational and/or security risk assessments performed by the aircraft operator, and aligned with the national
risk assessments issued by the authorities. It is important that is guidance is in additional to existing jurisdiction
regulations that permit hold bags to remain on-board upon factors outside of the passenger's control.

The Checklist for Aircraft Operators Accepting Unaccompanied Hold Baggage (2025) can be adapted into
operational checklists within Standard Operating Procedures (SOPs) to be followed by the ESPs responsible for
performing ground security measures on operators’ behalf under outsourcing agreements. An example of
adaptation into an Unaccompanied Hold Baggage Operational Risk Assessment Checklist (2025) for ESPs is
available in the SeMS Aviation Community2, under the dedicated SeMS Toolkit for ESPs folder.

Finally, the definition of outsourcing should be reminded as “the business practice whereby one party (e.g. an
operator or provider) transfers, usually under the terms of a contract or binding agreement, the conduct of an
operational function to a second party (e.g. an external service provider). Under outsourcing, the first party
retains responsibility for the output or results of the operational function even though it is conducted by the
second party” (IATA Reference Manual, IRM Edition 15, 2026).

In this context, outsourcing security measures to ESPs does not remove the aircraft operator’s responsibilities
outlined in international, regional and national security requirements.

4
ICAO Doc 8973 – Hold Baggage Screening, Handling and Processing (June 2025), paragraph B3.9
5
ICAO Doc 8973 – Hold Baggage Screening, Handling and Processing (June 2025), paragraph B3.12

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Checklist for Aircraft Operators Accepting Unaccompanied Hold

Baggage (2025)
1. Verification of Baggage Origin and Acceptance
a) Has the hold baggage been accepted only from passengers who have checked in for the flight or from crew
members on duty?
b) Has the hold baggage been accepted by a responsible agent or authorized representative of the aircraft operator,
with verified identity and valid boarding pass or crew ID?

2. Screening and Security Compliance

a) Has the hold baggage (including off-airport checked baggage) been screened at its point of origin using security
systems and appropriate standards of screening as defined by relevant authorities?
b) Has the hold baggage been protected from unauthorized interference from the point of screening or acceptance
until departure within security-restricted areas?
c) Has the integrity of the baggage protection been maintained and not compromised during handling or transfer?
d) If the integrity was jeopardized, has the hold baggage been re-screened to the appropriate security standards?

3. Baggage Tracking and Reconciliation

a) Has the hold baggage been correctly identified as accompanied or unaccompanied depending on the presence of
the owner on board?
b) Has the hold baggage been operationally tracked throughout the ground handling and flight journey to enable
reconciliation with its owner? (Baggage Manifest)

4. Operational Considerations for Offloading (also referred to as “factors beyond the passenger’s control”)
a) Has any hold baggage become unaccompanied due to the owner failing to board for unforeseen circumstances (e.g.,
short connection times, immigration)?
b) Has any hold baggage been misdirected, failed to transfer, or loaded onto an incorrect aircraft?
c) Has the aircraft operator made a documented decision not to load or unload baggage for operational reasons,
independent of passenger changes?
d) Has the owner voluntarily given up their seat?
e) Has the owner been denied boarding for security reasons?

5. Risk Assessment for Unaccompanied Hold Baggage

a) Has the operator conducted an Operational and/or Security Risk Assessment, prior to aircraft pushback,
considering all the questions above, in addition to the following ones:
i. Whether the unaccompanied baggage was previously screened to a defined high standard (e.g., advanced
screening technology)?
ii. Whether virtual rescreening by image review is feasible and adequate?
iii. What are the implications of any exceptions allowed by the State for carrying unaccompanied baggage
without additional screening or offloading?

6. Regulatory Alignment and Approvals

a) Has the operator coordinated with national regulators to ensure alignment with the latest ICAO guidance on Hold
Baggage Screening, Handling and Processing (June 2025) and local regulatory requirements?
b) Has the operator submitted data-driven risk assessments, pilot program proposals, and operational performance
metrics to regulators for approval of risk-based offload protocols?
c) Has the operator engaged with stakeholders (airports, External Service Providers) to develop performance-based
security protocols supporting the new baggage handling processes?

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