Take it up with the spec, then. That is the recommendation: > Section 6 of the 9303 part 3 document specifies transliteration of letters outside the A–Z range.

Take it up with the spec, then. That is the recommendation: > Section 6 of the 9303 part 3 document specifies transliteration of letters outside the A–Z range. It recommends that diacritical marks on Latin letters A-Z are simply omitted (ç → C, ð → D, ê → E, ñ → N etc.), but it allows the following transliterations: [...] You said > you might even get into legal trouble if you apply that. We're talking about passports, this seems not relevant. For passport-related use such as travel, you use the form of the name written on the passport, exactly as-is.