AEPD suspends biometric boarding gates at eight airports, Aena fined, AEPD enforcement

(SPAIN) Spain’s data protection authority has ordered biometric boarding gates at eight major airports to be shut down immediately and has fined airport operator Aena €10 million, in one of the toughest sanctions yet against facial recognition in Europe. The Agencia Española de Protección de Datos (AEPD) announced on 25 November 2025 that the programme violated European Union privacy rules and must be suspended. The decision affects systems at Madrid‑Barajas, Barcelona‑El Prat and six other airports that let passengers board flights by scanning their faces instead of showing passports or boarding passes.

Regulator’s findings and legal basis

AEPD investigators concluded that Aena failed to carry out a proper Data Protection Impact Assessment (DPIA) before rolling out the biometric boarding system beyond small pilots. They said the assessment the company did submit was:

• Inadequate
• Did not prove that collecting biometric data was necessary
• Ignored less intrusive options for managing boarding

Under Article 35 of the EU’s General Data Protection Regulation (GDPR), companies must perform a detailed risk study before using high‑risk tools such as facial recognition—especially when systems process sensitive information like unique facial patterns.

“The programme used biometric data even though less intrusive alternatives existed for the same purpose,” the AEPD said, adding that “the risks were not evaluated in depth, and the assessment was not done correctly.”

The watchdog’s order forces Aena to suspend all new enrolments and operations linked to biometric boarding gates, even as the company prepares for a surge in winter holiday traffic.

How the biometric boarding system worked

The system was initially piloted in 2022 and expanded between 2023 and 2024. Around 40,000 travelers signed up to have their faces linked with travel documents and frequent‑flyer accounts.

At participating gates:

• Registered passengers walked through biometric boarding gates.
• Gates compared live facial images with stored templates.
• Successful matches allowed boarding without showing a passport or phone.

Aena promoted the scheme as a way to:

• Speed up boarding
• Reduce queues
• Enable airlines like Iberia, Vueling and Air Europa to deliver smoother flows for frequent flyers and premium customers

Aena’s response and next steps

Aena said it “respectfully disagrees” with the AEPD on the legal analysis and the investigation process. The company asserts that:

• The project was fully voluntary
• Biometric templates were encrypted
• No security breaches or data leaks occurred during trials
• An impact assessment was carried out before scaling up

Aena has announced plans to appeal both the €10 million fine and the order to shut the programme down.

Current operational status and uncertainty

• For now, all biometric boarding projects at Spanish airports have been suspended.
• Passengers who already signed up are still allowed to use the service while legal arguments continue.
• The AEPD has not set a public deadline for when that transitional use must end, creating uncertainty for airlines that integrated the technology into premium products.

Aena had framed the initiative as a step toward more automated terminals, aligned with broader industry trends across Europe and other regions.

Timing and wider operational implications

The suspension arrives as Spain prepares for the EU’s new Entry/Exit System (EES), scheduled to start fully on 2 February 2026, which will register non‑EU travellers at external borders using fingerprints and facial images.

Aviation industry figures warn:

• Taking biometric boarding gates offline now could hinder management of the wider digital shift.
• This is especially concerning during the busy winter season when airports already struggle with long queues.

Although boarding systems and border‑control systems are separate, airport planners had hoped to use voluntary boarding trials to prepare staff and passengers for a more biometric‑heavy travel environment.

Broader European context and risks

The case feeds into a wider European debate about the use of biometric technologies in everyday settings such as airports, train stations and shopping centres. EU law treats biometric identifiers as especially sensitive because:

• Once a face template or fingerprint is compromised, it cannot be changed like a password or card number.

According to analysis by VisaVerge.com, data protection regulators across Europe have increasingly targeted experimental uses of facial recognition, insisting companies show:

• Systems are secure
• Systems are genuinely necessary

The Spanish watchdog’s ruling signals that airport operators will face especially close scrutiny, because travellers often feel they have little real choice when asked to hand over biometric data to catch a plane. The AEPD emphasised that:

• Even voluntary enrolment does not remove the need for a deeper risk assessment
• Authorities must consider less invasive tools
• There is an imbalance of power between large infrastructure operators and individual passengers, so strong safeguards are required when biometric processing is tied to essential services

Impacts on stakeholders

Privacy advocates across Europe view the Spanish case as a warning: even well‑publicised trials with tens of thousands of volunteers can trigger heavy sanctions if the paperwork is not watertight.

Airport executives are likely to worry about practical fallout if other regulators take similar lines, potentially slowing automation projects intended to:

• Cut costs
• Ease staff shortages

Operational consequences include:

• Continued traditional document checks at Spanish airports
• Airlines needing to explain changes and adjust boarding times
• Frequent flyers losing the convenience of biometric lanes

Legal and policy implications for future systems

The decision may influence how governments and airport operators design systems linked to the EU EES, even though border checks fall under separate legal regimes and often involve public authorities rather than private firms.

Legal specialists advise that operators will need to show in detail why they cannot meet operational goals with less intrusive tools, such as:

• Automated document readers
• Non‑biometric tokens

before turning to facial recognition or fingerprint scans.

Official guidance from the European Commission on data protection and travel technologies, available through the GDPR information pages on the European Union website, already stresses that any use of biometric data must be:

• Proportionate
• Secured
• Based on a clear legal need

(Reference: European Commission — GDPR information)

What Spanish travellers can expect

The immediate effects will be most visible at busy hubs like Madrid‑Barajas and Barcelona‑El Prat, where biometric boarding lanes had become common near gates used by major airlines.

• Some passengers may welcome the return to traditional checks, seeing them as less intrusive and easier to understand.
• Others will miss the speed and novelty of walking straight through a gate that recognises their face.

The dispute between Aena and the AEPD is likely to be litigated for many months. Courts will be asked to weigh commercial arguments about smoother airport operations against legal duties to minimise handling of sensitive personal data.

Key takeaways

The record €10 million fine and the sudden shutdown of biometric boarding gates at eight airports send a clear message: regulators across Europe are ready to intervene aggressively when privacy rules around facial recognition are not followed precisely. Spain has become a test case that other countries and airport groups will study closely as they decide how far to push biometric tools in pursuit of faster, more automated air travel.