Every Panama charter should carry a passenger list with each guest's full name and ID or passport number, stay within the AMP-certified capacity, and show the list when asked. Panama City operators are expected to report passengers to SENAN before departure, through their marina's procedure. Handle the data under Ley 81 of 2019.
The passenger list: what it is and who asks for it
A passenger list, or manifiesto de pasajeros, names everyone aboard for a trip. Three bodies may ask for it:
- SENAN, the Servicio Nacional Aeronaval, which patrols Panamanian waters and may board you. Panama City operators are expected to provide a passenger manifest before departure; the causeway station handles Amador operators, and your marina will tell you the current procedure.
- The AMP, whose inspectors check the vessel's certificates, licences and passenger capacity at the docks. In February 2026 the AMP announced sanctions after finding operators set to carry more passengers than their certificates allowed.
- The port captain, for any zarpe. For a day trip from Flamenco or La Playita to Taboga or Las Perlas and back, practice on domestic zarpes varies; ask the Balboa port captain what applies to your routes. See zarpe in Panama.
A law-firm summary of AMP practice adds that, for special events, companies must provide a list of participants, the planned distance and the schedule.
What to record for each trip
- Date, vessel name and registration, departure point and route, departure and return times.
- Captain and crew, with licence numbers.
- Each passenger's full name, nationality and ID or passport number; children marked as minors.
- Total aboard, checked against the certified capacity.
- An emergency contact for the group.
A draft tourism quality standard published by the commerce ministry in 2026 suggests a reservation record with each client's name, nationality, phone and number of people, and a client file for each service. Collect names and ID numbers at booking, then check the actual people and IDs at the dock. Anyone not on the list does not board.
IDs and passports
Panamanians and residents carry a cédula; most foreign visitors carry a passport. Ask guests to bring the original document they gave you at booking. Check the face against the document and the name against the list; you do not need to photocopy every passport unless the authorities or your insurer ask you to, and copying more than you need adds to what you must protect.
For trips that leave Panama, every guest also needs exit stamps from Migración, and the zarpe crew and passenger list must match.
Waivers and safety briefings
A signed acknowledgement does not replace insurance or a safe operation, but it records that the guest heard the safety briefing, knows where the life jackets are, and accepted the rules on alcohol, swimming and the captain's authority. Keep it short, bilingual and specific to the trip. How far a waiver protects you under Panamanian law is a lawyer's question; see charter liability insurance and waivers.
Record the briefing as given: time, who gave it, and that every guest was present.
Personal data under Ley 81 of 2019
Passenger lists are personal data. Ley 81 of 26 March 2019 and its regulation, Decreto Ejecutivo 285 of 2021, apply, with the transparency authority ANTAI as regulator.
- Consent and purpose. Collect data with the guest's prior, informed consent, or another legal basis such as a legal obligation, and only what the purpose needs. Say why you collect it: safety, the authorities' passenger list, invoicing.
- Sensitive data. Health information, such as allergies or medical conditions, is sensitive. Ask only when you need it for safety, with explicit consent.
- Security. Limit who can see the lists, and do not leave them in group chats. If data is exposed, the law expects you to inform the people affected as soon as possible.
- Third parties. The regulation added a registry for databases transferred to third parties. Ask your lawyer whether sharing lists with platforms, marinas or agents triggers it.
- Sanctions. LexLatin reported fines of US$1,000 to US$10,000 and possible suspension of data processing.
Marketing to past guests needs separate consent.
How long to keep records
No single period covers everything. Work it out record by record:
- Passenger lists and briefings: long enough to answer an incident, an insurance claim or an inspection. Ask your insurer and lawyer for the period, then delete.
- Bookings and confirmations: the draft tourism standard checks records for the last 12 months and says reservation data should be deleted after the legally necessary period.
- Invoices and accounting records: as long as tax law requires. Ask your accountant.
- Payment disputes: until your card processor's dispute window has closed; see bookings, deposits and payments.
Ley 81's purpose principle means you should not keep personal data longer than necessary. Write the periods down and delete on schedule.
Your practical starting checklist
- Collect each guest's full name, nationality and ID or passport number at booking.
- Check people and documents against the list at the dock, and never exceed certified capacity.
- Ask your marina and the SENAN station for the current manifest procedure, and follow it for every departure.
- Ask the Balboa port captain whether your routes need a domestic zarpe.
- Give and record a safety briefing, with a short bilingual acknowledgement.
- Write a privacy notice and retention schedule under Ley 81, and delete records on schedule.
Frequently asked questions
Do I need a passenger manifest for a day trip from Flamenco or La Playita?
Keep one for every trip. Panama City operators are expected to give SENAN a passenger list before departure; ask your marina for the current procedure, and ask the Balboa port captain whether a domestic zarpe is needed.
Can I keep copies of guests' passports?
Only if you need them. Recording the passport number and checking the document at the dock is usually enough. Anything you copy is personal data you must protect under Ley 81 of 2019.
Does Panama's data protection law apply to a small charter?
Yes. Ley 81 of 2019 applies to anyone who collects personal data, with ANTAI as regulator. Collect only what you need, with consent, and keep it secure.
Does a signed waiver protect my charter business?
It records that the guest was briefed and accepted the rules, but it does not replace insurance or safe operation. Ask a Panamanian lawyer how far it protects you.
¿Qué debe llevar el manifiesto de pasajeros de una embarcación en Panamá?
Fecha, embarcación, ruta, capitán y tripulación, y el nombre completo, nacionalidad y número de cédula o pasaporte de cada pasajero, sin superar la capacidad del certificado de la AMP. Pregunte a su marina cómo se entrega al SENAN.
En español: manifiesto de pasajeros y datos personales
Lleve una lista de pasajeros en cada salida, con nombre completo y cédula o pasaporte, y nunca supere la capacidad del certificado de la AMP. Pregunte a su marina y a la estación del SENAN en la Calzada de Amador cuál es el procedimiento vigente. Los datos de los pasajeros están protegidos por la Ley 81 de 2019: pida solo lo necesario, con consentimiento, y bórrelos cuando ya no los necesite.
The next question to answer
The full startup chain. Read How to start a boat charter business in Panama.
Domestic vs international clearance. Read Zarpe in Panama.
The capacity your list is checked against. Read Passenger limits on Panama charter boats.
Same topic in Florida: coming from the US? Compare Customer Identification and Data Retention.
Official resources
Use the relevant Panamanian authority for current requirements and fees. These resources are the next place to check; a practical recommendation is not an agency determination.
- Kraemer & Kraemer: Law 81 of 2019 on personal data protection (secondary, law-firm summary) ↗
- LexLatin: publican reglamento de la ley de protección de datos (DE 285 de 2021), Jun 2021 (secondary) ↗
- La Prensa: Carnavales 2026, AMP detecta exceso de pasajeros en lanchas (secondary, press) ↗
- Kraemer & Kraemer: Panama yacht charter regulations (secondary, law-firm summary) ↗
- MICI / DGNTI: draft technical norm on tourism quality, land and maritime transport (2026) ↗