At the request of the European Passengers’ Federation and its Dutch member organisation Rover, the Meijers Committee – a group of distinguished lawyers in the Netherlands – has written a note on the application of PNR rules in the railway sector.

According to the Meijers Committee, extending the scope of application of PNR rules beyond air transport (cf. PNR Directive 2016/681) may not be in accordance with all requirements of EU law. Before adopting any such legislative instrument, a privacy impact assessment should be conducted as well as a necessity and proportionality test, taking into account the principle of free movement in the EU internal market.