RPE and Compliance: From Source to Reliable Records

The role of the Boarded Passenger Report in the airport context

In the Brazilian civil aviation ecosystem, airport administration requires the continuous recording of aircraft, passenger, and cargo flows. Infraero's 2016 Operational Statistical Yearbook describes the Boarded Passenger Report (Relatório de Passageiros Embarcados - RPE) as a form completed by airlines to provide data to airports then managed by the company. As recorded in Infraero's 2016 Operational Statistical Yearbook, the information was processed and consolidated by Infraero to compile its traffic statistics.

However, the regulatory environment has evolved. The yearbook also notes that ANAC Resolution No. 8/2007 revoked the previous requirement under Ordinance 602-GC5 for airlines to submit the RPE to airports. This does not allow assuming a general obligation to submit this form today: applicable procedures must be examined according to the operator, contracts, and relevant regulations. It is essential to conceptually distinguish the RPE, which covers the operational details of the passenger boarding manifest, from the Airport Exploitation Plan (PEA), a document that is part of concession agreements and governs infrastructure parameters and service levels. Accuracy in this distinction ensures that data governance is approached from the correct perspective of operational and tariff control.

From data origin to frequent causes of divergence

The generation of primary traffic data occurs at multiple points along the operational chain. Airlines record the number of seats sold, the number of completed check-in tickets, and, finally, the passengers who actually passed through the boarding gates. Simultaneously, ground teams and airport operations centers record landings, takeoffs, occupied apron positions, and ground times through flight control systems and ground radars.

Inconsistencies between what the airline reports and what the airport operator observes have well-defined origins:

• Cut-off time differences between manifest finalization in the airline system and aircraft door closure.
• Transit and connecting passengers not uniformly distinguished in direct connection records.
• Last-minute cancellations of passengers who checked in but did not board (gate no-shows).
• Runway returns resulting from unscheduled maintenance or adverse weather, generating new takeoff clearances without changes in boarding volume.
• Manual data entry errors in operational connections that still rely on decentralized input.

These gaps require airport management to establish systematic cross-checking routines so that raw data is verified against independent sources before consolidating definitive records.

The structured chain: raw data, reconciliation, and billing

Maturity in data management requires a clear separation between the phases of capture, verification, tariff rule application, and reporting. Conflating these stages compromises both financial health and the infrastructure's registration integrity.

The cycle is divided into four functional phases:

1. Primary data collection: reception of airline operational files, flight plans, and ground telemetry without prior editing.
2. Operational reconciliation: cross-referencing declared runway movements, block times, and reported passenger totals, identifying deviations and discrepancies.
3. Tariff application: application of applicable airport charges (boarding, landing, parking) as regulated by the respective concession agreement, tariff ordinance, or formal act applicable to the aerodrome.
4. Consolidation and reporting: issuance of invoiced billings and structuring of statistical statements required by granting authorities and regulators.

No tariff should be applied directly to unreconciled raw data. This operational separation protects the airport against improper charges and prevents prolonged financial disputes.

Traceability, audit trail, and operational governance

Maintaining a reliable and auditable archive is a core principle in civil aviation. ANAC's RBAC 153 Amendment 09, in section 153.39, establishes that the aerodrome operator must maintain documents demonstrating compliance with applicable requirements, ensuring that such records remain traceable, easily identifiable, and with properly controlled revisions. Section 153.119(c) addresses the control and recording of movements in the processing of aircraft, passengers, air cargo, and airmail. The application of requirements must be verified according to the operational classification.

The existence of a digital audit trail constitutes indispensable technical support to demonstrate process integrity. However, technological tools alone do not ensure automatic regulatory compliance, as compliance depends on the strict execution of approved procedures by responsible teams and adherence to applicable guidelines.

When evaluating an airport management platform, it is important to check whether the process allows querying the original received versions, distinguishing subsequent modifications, and locating their justifications. This facilitates evidence preparation, but actual capability depends on the configuration and procedures adopted by the operator.

Change control and division of internal responsibilities

The accuracy of operational records depends on internal governance with clear authority levels across different airport departments. In established corporate structures, responsibilities are distributed in a coordinated manner:

• Operations and Airport Operations Center (AOC): responsible for validating physical aircraft movement data, actual operational times, boarding bridges used, and apron positions.
• Billing and Finance: responsible for checking applicable tariff rules, validating exemptions provided by regulations, and issuing billing documents.
• Governance, Risk, and Compliance: responsible for the continuous verification of data retention policies, record integrity, and management of audit trails.

As a governance practice, any subsequent rectification must preserve the original record and document who made the change, when, why, and based on what evidence. A verifiable history helps explain decisions; it does not by itself eliminate errors, disputes, or the need for supervision.

Illustrative workflow for information processing

To illustrate governance without using fictitious data, consider the following conceptual information processing workflow:

• Step 1: The team receives passenger information from the air operator when made available and records the data source. If an RPE form is not available, it identifies another applicable document or procedure.
• Step 2: The team compares the received information with available movement records. Verification may be manual or system-supported; it does not assume sensors or integrations present at every airport.
• Step 3: If a discrepancy arises, the responsible teams identify the point of disagreement, preserve available versions, and determine who should investigate the occurrence.
• Step 4: The team evaluates available documents and, if necessary, consults the air operator. The conclusion and its justification are documented according to the airport's routine.
• Step 5: After reconciliation, the validated record can support the application of relevant tariff rules and the preparation of applicable reports.

For concession managers, evaluating software for airport concessionaires must consider how operational data, billing rules, and human verification connect. No system replaces validating the specific obligations of each contract.

Essential questions for oversight and record integrity

During operational and accounting audits, both internal and external, movement data consistency is put to the test. Managers must be prepared to answer structural questions technically:

• Where is the original file received from the airline stored, and how is it ensured that it has not undergone subsequent alterations?
• What operational criteria were used to justify the manual adjustment of a boarded passenger count?
• Does the database allow individual correlation of each billed flight to its respective flight plan and ground record?
• Did the applied billing rules adhere to the formally published tariff brackets and categories for the flight date?
• Upon request by the regulatory authority, are movement records from previous years readily retrievable and consistent?

The airport operation case studies help compare management contexts, but do not replace verifying the rules and evidence specific to each operation.

Specifics between scheduled aviation and general aviation

The collection and processing of operational data differ substantially depending on the segment served by the airport. In scheduled commercial aviation, standardized data integrations predominate, with concentrated passenger volumes and predefined schedules.

On the other hand, in general and business aviation, the diversity of operators, non-scheduled flights, and small to mid-sized aircraft poses additional challenges:

• Identifying the party responsible for the aircraft and tariff payment often occurs during apron handling.
• Completing boarding and parking forms may involve manual processes by fixed-base operators (FBOs) or apron inspectors.
• Schedule volatility requires rigorous daily reconciliation to prevent revenue loss or incorrect billing.

Additionally, precise knowledge of traffic profiles supports long-term analytical studies, such as airport demand forecasting analysis, a potential input for planning apron, terminal, and runway capacity.

Considerations on operational data governance

Structuring a reliable repository of passenger and flight data transcends bureaucratic obligation: it is a strategic asset for airport governance. From the proper receipt of the RPE and equivalent records to the accurate application of contractual tariffs, every link in the process contributes to transparency across the aviation sector.

By aligning rigorous internal processes, clear allocation of duties between operations and finance, and technological support geared toward traceability, the airport operator establishes a solid historical foundation capable of supporting audits, substantiating investment decisions, and organizing evidence for compliance review before regulatory bodies.

Sources and references

• Infraero. *Anuário Estatístico Operacional 2016*. Infraero, publication for 2016. Available at: https://www.infraero.gov.br/images/stories/Estatistica/anuario/anuario_2016.pdf
• Agência Nacional de Aviação Civil (ANAC). *Regulamento Brasileiro da Aviação Civil - RBAC nº 153, Emenda 09: Aeródromos - Requisitos Operacionais*. ANAC. Available at: https://pergamum.anac.gov.br/pergamum/vinculos/RBAC153EMD09.pdf