Air Operations

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Air Operations - General

In the definition of ‘commercial operation’ published in Art. 2 of Regulation (EU) 965/2012 (introduced by the amending Reg. (EU) 2018/1975), what is the meaning of the term “control”?

Would there be a restriction that requires baby bassinets to be removed and stowed during in-flight turbulent weather conditions? Where is it documented?

What are the essential requirements?

What do 'grandfathering', 'transition measure' and 'opt-out' mean?

What is the difference between 'entry into force' and 'date of applicability' in the Cover Regulations?

When will the new rules on air operations be applicable?

What is the comitology procedure?

Why can't I find EU-OPS on the EASA website?

What is the status of 'Implementing Rules', 'Acceptable Means of Compliance' (AMC), ‘Certification Specifications’ (CS), Alternative Means of Compliance (AltMOC), 'Guidance Material' (GM), ‘Special Conditions’ and 'Frequently Asked Questions'(FAQ)?

Does Reg. (EU) No 965/2012 on air operations also apply to non-commercial operations?

I am not familiar with the Air ops rules’ structure. Which parts apply to which operators?

How can I find out where a rule from EU-OPS / JAR-OPS 3 has been transposed in the new Regulation (EU) 965/2012 on Air Operations and its amendments, as well as its associated EASA Decisions, and if any changes have been introduced?

Which operational requirements (EU/EASA Parts) apply to flight activities carried out by an aircraft designer or aircraft manufacturer?

Where can I find a list of alternative means of compliance that have been adopted by operators and NAAs in the EU?


What are critical phases of flight?

What are 'Sterile Flight Deck Procedures'?

What is the difference between 'commercial operation' and 'commercial air transport (CAT) operation'?


AMC2 ARO.GEN.305(c) Oversight programme (c) stipulates that audits should include at least one on-site audit within each oversight planning cycle. What is meant by an 'on-site audit' in this sentence? Could it be so that every audit undertaken by an NAA could be performed while sitting in the NAA's office and reviewing operator's documents and procedures and only one of those audits should be undertaken in a way that NAA inspectors actually visit an operator on-site?

How do the provisions on wet-leasing articulate with Regulation (EU) No 452/2014 on Third Country Operators (TCO)?

Must the competent authority check and approve the content of the operator's Safety Management Manual?

How do the provisions on code-sharing articulate with the Regulation applying to Third Country Operators (Part TCO)?



ORO.GEN.110 (a): “The operator is responsible for the operation of the aircraft in accordance with Annex IV to Regulation (EC) No 216/2008”. Is this requirement met when an Operator follows the Implementing Rules (965/2012)?

What are the responsibilities of the AOC holder required to implement a management system in accordance with ORO.GEN.200 in regards to continuing airworthiness management and contracted maintenance?

Is there a difference between safety risk management (SRM) and SMS?

Why do the EASA Air Operations rules use the term ‘management system’ (ORO.GEN.200) and not ‘safety management system’ (SMS), like in ICAO Annex 19? Is there a difference between the two concepts?

If an operator is considered complex , may a person hold the position as a Safety Manager and at the same time be one (or more) of the nominated persons as described in ORO.GEN.210(b), taken into account the size and complexity of the operator?

I am looking for the acceptance of post holders, particularly the Safety manager. In the AMC we agreed on the functions of the Safety manager, but did we agree on his or her acceptance?

Regarding ORO.GEN.200, could a commercial operator of complex motor powered aircraft, such as the Cessna Citation Bravo that operates within Europe and with no SPAs, be considered non-complex?


How should an operator use external material in relation with its operations manual (OM)?


Status of the EASA FAQ: What is the legal status of the EASA FAQ? My own understanding of this document is that it has no legal standing at all, insofar as it is neither an Implementing Rule (IR), Acceptable Means of Compliance (AMC), Alternative Means of Compliance (AltMoc) nor even Guidance Material (GM).

Applicability of FTL requirements of Regulation (EU) No 965/2012: Why should we comply with the FTL requirements of Regulation (EU) No 965/2012, since we have a policy in our company that says otherwise?

Applicability of Regulation (EU) No 965/2012: What is the meaning of "applicable national flight time limitation legislation" in Article 8 (4) of Regulation 965/2012?

Collective Labour Agreements (CLA) - Regulation (EU) No 83/2014: Our company has a Collective Labour Agreement (CLA) and an approved IFTSS. Both contain rules about FPD’s, DP’s and rostering. Which one is leading?

Applicability of Subpart FTL (see also ORO.AOC.125): Does Subpart FTL apply in relation to non-revenue flights (ferry flights)?

Acclimatisation ORO.FTL.105(1): How should we determine the state of crew member acclimatisation in complex rotations?

Accommodation ORO.FTL.105 (3): Can the airport crew lounge be considered as “accommodation” for the purpose of standby or split duty? Can a hotel room for several crew members of the same gender be considered as “accommodation” for the purpose of standby and split duty?

Disruptive schedule ORO.FTL.105(8): Which criteria should be applied to determine a duty as disruptive if there is a time zone difference between the reporting point and the place where the duty finishes?

Definition of duty and duty period, ORO.FTL.105 (10), ORO FTL 105 (11): Must the time for self-preparation (e.g. preparing for the checks associated with initial or recurrent training) be entered in the schedule of the crew members and recorded?

Single day free of duty ORO FTL 105 (23): A ‘single day free of duty’ consists of one day and two local nights. Does the last day of several consecutive days free of duty need to contain at least one day and two nights?

Sector ORO.FTL.105 (24), (see also ORO.FTL.205 (f)(6)): In an abnormal or emergency situation a take-off might not be executed meaning that a sector was not completed. Such situation is likely to increase flight crew workload and fatigue. How could this be mitigated?

Changes to a published roster: Is it possible to make changes to a published roster?

Change of FDP after reporting: Can a rostered FDP be changed (re-planned) after crew members have reported?

Roster publication, (see also AMC1 ORO.FTL.110(a) and ORO.GEN.120): Are airline operators allowed to publish monthly rosters in less than 14 days in advance?

Reporting times ORO.FTL.110(c), (see also ORO.FTL.205(c)): Can the pre-flight reporting time for non-augmented flight crew members reporting for the same FDP be different?

Operational robustness ORO.FTL.110(j): How should operational robustness be assessed?

Flying activities outside an AOC (see also ORO.FC.100): How will activities as an instructor or an examiner performed by an operating crew member in their free time be considered for the purpose of duty time and rest periods?

Deviation from the applicable CS ORO.FTL.125 (c) (see also ARO.OPS.235): What does a deviation from the applicable CS mean or derogation from an implementing rule?

Flight time specification scheme for air taxi operations, (see also Articles 2 (6) and 8(2) of Regulation (EU) no 965/2012): An air taxi operator has both an aeroplane with less than 19 seats and one aeroplane with more than 20 seats. What FTL regulation shall the crew who is flying both types follow?

Approval of Individual Flight Time Specification Schemes (IFTSS), (see also ARO.OPS.235):

Unknown state of acclimatisation GM1 ORO.FTL.205(b)(1): If the crew member is in an unknown state of acclimatisation, what is the reference time?

Unknown state of acclimatisation ORO.FTL.205(b)(3): What are the daily FDP limits when crew members are in an unknown state of acclimatisation under fatigue risk management (FRM)?

Mixing FDPs extended without in-flight rest and FDP’s extended due to in-flight rest ORO.FTL.205 (d) ORO.FTL.205 (e): Is it possible to roster two extended FDPs without in-flight rest and one extended FDP with in-flight rest in 7 consecutive days?

Planned FDP extensions ORO.FTL.205(d): Must planned extensions be included in the operator’s roster?

Planned FDP extensions ORO.FTL.205(d) (see also ORO.FTL.105(1)): Can a crew member acclimatised to the local time of the departure time zone (‘B’ state), but not acclimatised to the local time where he/she starts the next duty (‘D’ state), be assigned a planned extended flight?

Commander’s discretion ORO.FTL.205(f): Do we need to use Commander’s discretion if actual FDP is going to last more than planned but less than the maximum daily FDP allowed?

Commander’s discretion ORO.FTL.205(f): When should commander’s discretion be used?

Commander’s discretion ORO.FTL.205(f), (see also ORO.FTL.205 (d)): 1. What is the maximum FDP extension allowed under commander’s discretion? 2. How would commander’s discretion apply when the FDP of a non-augmented crew has already been extended in accordance with ORO.FTL.205 (d))?

Commander’s discretion ORO.FTL.205(f): Referring to commander’s discretion, do I need to consider the reporting time and number of sectors?

Conversion/line checks Post flight duty ORO.FTL.210: How should briefings and debriefings during conversion/line checks be accounted for?

Post-flight duty AMC1 ORO.FTL.210(c): What should the operator do if the actual post flight duty time is longer than the established time in the OM?

Positioning for purposes other than operating ORO.FTL.215 (b): How should time spent to travel from the place of rest or home base to a simulator (when outside the base) be taken into account?

Positioning ORO.FTL.215: Does positioning begin when the crew member arrives at the airport/train station or when the aeroplane/train leaves?

Positioning ORO.FTL.215: Shall a positioning between active sectors count as a sector for a pilot or cabin crew?

Split duty ORO.FTL. 220: Is it possible to have more than one split duty within one FDP?

Standby ORO.FTL.225(a) (see also CS FTL.1.225 and GM1 CS FTL.1.225(a)): Can a standby be finished before the planned “end time notified in advance”, after a notification during the standby (saying that there will be no assignment) and the rest period be initiated at the time of the notification of the new standby end?

Reserve ORO.FTL.230: Can a reserve, during which no flight was assigned, be considered as a day off afterwards?

Rest prior to an FDP ORO.FTL.235 (a): If a crew member with office duties spends one day in the office, what should be the duration of the rest before his/her reporting for an FDP?

Rest prior to a duty other than FDP ORO.FTL.235 (a): What is the duration of the rest period prior to a duty without FDP?

Reduction of recurrent extended recovery rest by commander’s discretion ORO.FTL.235(d) (see also ORO.FTL.205(f)): Can the extended recovery rest period be reduced with commander’s discretion?

Increase of interval between two recurrent extended recovery rest periods by commander’s discretion ORO.FTL.235(d) (see also ORO.FTL.205(f)): May the crew member exercise his/her discretion to finish back at home base exceeding the 168 hours’ time between two extended recovery rest periods? For example, a crew member is planned to finish his last FDP flying back to home base, two hours prior to reaching 168 hours. There is a departure delay which occurred after reporting. As a result, the crew member would exceed the 168 hours by 1 hour.

Increase of interval between two recurrent extended recovery rest periods ORO.FTL.235(d): Can the 168h limit between two extended recovery rest periods be extended? For example, a crew member reports at Paris on Monday at 7am and ends a series of flights in Singapore, on Sunday, at 8 pm; he/she should be given his/her extended recovery rest period in Singapore, but might be willing to come back to his/her base, hence infringing the 168h limit through positioning.

Re-planning of recurrent extended recovery rest period ORO.FTL.235 (d): Is re-planning of a recurrent extended recovery rest period allowed and when?

Record keeping ORO.FTL.245: Do records required in ORO.FTL.245 have to reflect planned or actual FDP, DP and rest?

Home base change CS FTL.1.200(b): Is it correct to understand that if a crew member is asked to report for an FDP at a reporting point other than his/her home base without extension of his/her recurrent extended recovery to 72h incl. 3 local nights, immediately prior to that FDP, the home base has not been changed for the purpose of Subpart FTL?

Consecutive night duties CS FTL.1.205(a)(1): What does ‘consecutive’ mean in the context of the requirements and limits of CS FTL.1.205?

Night duties CS FTL.1.205(a)(2), (see also GM1 CS FTL1.205 (a)(2)): Is it necessary to have an ‘approved’ FRM to operate long night duties (FDP over 10hrs)?

In-flight rest CS FTL.1.205(c) : Is it possible to extend the FDP, if not all pilots get an in-flight rest?

Maximum daily FDP with the use of extensions due to in flight rest CS FTL.1.205(c)(2): Why does the ‘maximum daily FDP with the use of extensions due to in flight rest’ not take into account the start of FDP at reference time?

Delayed reporting CS FTL.1.205(d)(1): Is it possible to inform crew members of a delay without giving the new reporting time?

Delayed reporting CS FTL.1.205(d)(1)(iii): Why does delayed reporting with a delay of less than 4 hours not account for the WOCL? Is there any scientific evidence for this?

Split duty (see also ORO.FTL.205 (b)(2) and ORO.FTL.220): Can split duty be scheduled when crew members are in an unknown state of acclimatisation?

Split duty CS FTL.1.220 (b): Are the 30 minutes for post and pre-flight duties as well as travelling counted in total or 30 min for post flight duties, 30 min for travelling after post flight duties, 30 min for travelling before pre-flight duties and 30 min for pre-flight duties?

Split duty CS FTL.1.220(d): Should suitable accommodation be provided for a split duty?

Rest after airport standby or other-standby CS FTL.1.225 (a)(1)& CS FTL.1.225 (b)(4): What is the basis for rest calculation after a standby followed by an FDP? Is it the reporting time for standby or the “actual reporting time” for the assigned FDP?

Airport standby CS FTL.1.225 (a)(2)(ii): Why does CS FTL.1.225 (a)(2)(ii) not stipulate the maximum duration of airport standby?

Airport standby CS FTL 1.225(a)(2)(ii), (see also ORO.FTL.205 (b)&(d); CS FTL 1.205 (a) (2)): We understand that the limit of 16 hours is not applicable when airport standby is followed by a FDP with in-flight rest. Does that mean that there is no limit for that kind of situation?

Other-standby followed by an FDP CS FTL.1.225(b)(2): How shall an operator expect a crew member to use whole or part of a standby for sleep when there are disturbance factors like difficulty to fall asleep, disturbed sleep due to sick children, waking-up by external noise, etc.?

Awake time CS FTL 1 225 (b)(2): Who is responsible for making sure that the 18h are not exceeded? The crew member or the operator? Can the operator fully transfer the responsibility to the crew member?

Other-standby CS FTL.1.225(b)(2), (see also CAT.OP.MPA.210(a)(3)): Would using a controlled rest procedure while the flight crew member is at his/her assigned station break the 18-hour awake time?

Other-standby CS FTL.1.225(b)(3): How is the time spent on other-standby before an assignment accounted for?

Other-standby CS FTL.1.225 (b), (see also ORO.FTL.105 (25)): Is it possible during other-standby to assign an FDP with a reporting time after the rostered end of that standby period has elapsed?

Other-standby modified to airport standby CS FTL.1.225, (see also ORO.FTL.105 (25)): Can other-standby be modified to airport standby during the standby? For example, can a pilot on home standby be required to go to the airport to continue on airport standby? What limits must be used?

Reserve and other-standby CS FTL.1.230: While a crew member is on reserve, can his/her assignment be changed and continue as a home standby?

Reserve CS FTL 1.230(b): Is there any rest requirement after a reserve period, if there is no assignment of duty period during the reserve?

Reserve CS FTL.1.230 (d): Is it necessary to have an FRM to protect an 8-hour sleep opportunity during reserve?

Reserve CS FTL 1.230(d): Should the period of 8 hours run consecutively or is it possible to break it in two different periods?

Rest between disruptive schedules CS FTL.1.235(a)(1), (see also ORO.FTL.105(8)): The rule for transition between late finish/night duty and early start says that the rest between the FDPs needs to include a local night. Does this mean that the rule only applies if the late finish/night duty and the early duty are FDP’s?

Rest compensation for time zone differences CS FTL.1.235(b)(3)(i): How should we count the time elapsed (h) since reporting for the first FDP in a rotation involving at least 4 hour time difference to the reference time?

Reduced rest CS FTL.1.235(b)(3)(ii), (see also ORO.FTL.235 (c) and (e)): Is it possible to reduce the 14h rest away from home base following an FDP involving a 4-hour time difference or more?

Rest to compensate for time zone differences CS FTL.1.235(b)(4): What does Eastward-Westward or Westward-Eastward transition mean?

Monitoring Time Zone Differences CS FTL.1.235(b)(5): Does the requirement to monitor combinations of rotations require FRM in accordance with ORO.FTL.120?

Reduced rest CS FTL.1.235(c)(5): Is it possible to apply reduced rest to two consecutive rest periods?

Nutrition ORO.FTL.240: Are nutrition provisions subject to a specific NAA's approval and can they be documented elsewhere in the OM-A, not necessarily Chapter 7.

Fatigue management training ORO.FTL.250 AMC1 ORO.FTL.250: What should be the minimum requirements for a fatigue management instructor? Is a CRMi course enough? Is a safety manager ready and without other training to deliver a course? Can someone that has received a few hours course in accordance with AMC1 ORO.FTL.250 repeat the course to others?

Reporting point ORO.FTL.105 (2): The global COVID-19 pandemic necessitated, on a number of occasions, a change to the typical aircrew reporting point. How should the operators address this change?

Individual crew members’ records of flight time and duty periods ORO.FTL.245, (see also ORO.FTL.105):

Must the time for all training at the behest of the operator be entered in the schedule of the crew members and recorded?

Passenger Safety

Use of baby bassinets on board

Use of baby bassinets on board

Use of Child Seats on Board

Can I use a child seat on board for my baby/child? What about a rear-facing child seat?

Passenger safety briefing

Is there any requirement on what language(s) should be used for information provided to passengers via safety briefings and announcements?


Are there any requirements for loadmasters?

Referring to Annex II - AMC 20-6 rev.2, on ETOPS Applicability, is ETOPS approval required or not for aircraft with a seating configuration of 19 or less and a maximum take-off mass of less than 45 360 kg and not exceeding 180 minutes at the approved one-engine-inoperative speed (in still air) from an adequate aerodrome?

NPAs CDFA-SA with IAP instrument approach procedure expressing minima as a "DA/H" should have an "ADD-ON" or not? Am I allowed to go a little bellow the "DA/H" while performing a missed approach/going around?

What is the meaning of ‘where applicable’ in relation to the data link recording requirements in CAT.IDE.A.195, CAT.IDE.H.195, NCC.IDE.A.170, NCC.IDE.H.170, SPO.IDE.A.150 and SPO.IDE.H.150?

AMC1 (a) to CAT.IDE.A.280 says, “Batteries used in the ELTs should be replaced (or recharged, if the battery is rechargeable) when the equipment has been in use for more than 1 cumulative hour”. What should be understood by “in use for more than 1 cumulative hour”?

Does the operator need an exemption to CAT.OP.MPA.160 to use the passenger cabin as a cargo compartment?

Is there any regulatory statement by which it is required for all European aeroplanes to carry a defibrillator on board?

What are the obligations when carrying AED’s (Automated Emergency Defibrillators) on board as per CAT.IDE.A.220 and CAT.IDE.A.225?


SPA.HEMS.110 Equipment requirements for HEMS operations specifies: "The installation of all helicopter dedicated medical equipment and any subsequent modifications and, where appropriate, its operation shall be approved in accordance with Regulation (EC) No 1702/2003". Does it mean that even a defibrillator or an oxylog has to be approved in accordance with Regulation (EC) 1702/2003 or (EU) 748/2012? Or does it mean that only the fix installed medical equipment, such as a stretcher or a fix provision, has to be approved?

Dangerous Goods

Is there a European regulation on dangerous goods training requirements or should each European country follow its own national regulations?

Q2: What are the rules concerning the carriage of portable air concentrators (POC) on board? Can they be used during the whole flight?

Q1: What are the rules for passengers using bottled oxygen on board an aircraft?

Which operators have to establish and maintain dangerous goods training programmes? Which training programmes should be approved by the authority?


Are there differences between the European Air Ops rules for NCC and ICAO SARPs?

Do NCC operators with non-EU registered aircraft need to maintain two different Operations Manuals?

My operations manual (OM) uses a template provided by a recognised industry standard. Is this sufficient for me to be compliant with the rules?

What is the intent of the declaration?

How can an NCC operator establish if its organisation is complex or non-complex?

Is the European State of the Operator principle for NCC operations in contradiction to the Chicago Convention?

Is a CAMO required for a European NCC operator using a third-country registered aircraft?

Why are non-commercial operations treated in two Parts, i.e. Part NCC (non-commercial with complex motor-powered aircraft and a Part NCO (non-commercial with other-than-complex motor-powered-aircraft)?

Which requirements does an ATO need to follow? Is Part ORO applicable?

What is the meaning of the term NCC?

Which is the competent authority responsible for the oversight of the NCC operations in Europe?

Which Annexes of Regulation (EU) No 965/2012 are applicable to NCC operations?

May a European NCC or NCO operator use third-country registered aircraft?

Which pilot licence is required for flying a third-country registered aircraft in the EU?

Why do European rules require a list of specific approvals?

Do the European rules recognise if an operator conforms to European industry standards?

How should I start building my SMS if I have a very small organisation (up to 2-3 persons) and I operate a complex aeroplane or helicopter?

We are an aero-club authorised by Member State X to perform skydiving operations. We operate a non-complex aircraft dry-leased from an operator registered in Member State Y. Our skydivers and the tandem passengers are registered members of the aero-club; there is no profit distributed outside our organisation. Which Parts of Regulation (EU) 965/2012 apply to us? Which is our competent authority?

Does an NCO operator established in an EU Member State and operating an aircraft registered in a third country need to comply with the Airworthiness Directives (AD) issued by EASA, in addition to the ADs issued by the State of Registry?


How to distinguish between a ‘commercial’ SPO operator and a ‘non-commercial’ SPO operator?

Are we a ‘complex’ or ‘non-complex’ operator considering the fact that we have five FTEs and four types of non-complex helicopters?

Can I use third-country registered aircraft for my SPO operations?

We operate a helicopter that is Annex II aircraft according to the Basic Regulation. How should we continue to conduct SPO now? Do we need any exemption?

Why may a SPO operator not carry on board passengers on an aerobatic flight?

Now, thanks to Art. 6 (8) of Reg. (EU) 965/2012, I operate non-commercially a twin turbo-propeller aircraft below 5.7 t MCTOM in accordance with Part-NCO. May I also carry out non-commercial specialised operations with the same aircraft under Part-NCO?

Is it permissible for me to determine myself whether the operations I conduct are eligible for the alleviation of SPO.GEN.005 (c)?

What do the terms ‘marginal activity’, ‘direct cost’, ‘annual cost’ and ‘organisation created with the aim of promoting aerial sport or leisure aviation’ mean?

Are we high-risk or non-high-risk commercial specialised operator?

Do I need two authorisations, if the lists of high-risk commercial SPO of different Member States differ?

What is the meaning of "applicable national flight time limitation legislation" in Article 8 (4) of regulation 965/2012?

My SPO operations fall under Part-SPO. What type of certification shall I expect from my competent authority – AOC or other type?

Who must submit a declaration?

Is the skydiving activity itself under the scope of Regulation (EU) No 965/2012?

Can I fly an aeroplane for commercial parachute dropping operation with my PPL (A)?

Is 'MOPSC' (Maximum Operational Passenger Seating Configuration') applicable in case of parachute dropping, where only task specialists are carried?

How is a ramp inspector supposed to know the nature of a particular SPO flight (commercial or non-commercial)?

If I hold an AOC and want to perform SPO activities (commercial and non-commercial) with the same aircraft registered on my AOC, do I have to submit a declaration too?

Must an operator holding specific approvals (SPAs) for its CAT operations apply for the same SPAs when it also conducts specialised operations?

Is it allowed to perform specialised operations with a permit-to-fly or is a CofA mandatory at all times?

Can we integrate the processes for a permission under Part-SERA and with high-risk authorisation (HRA) under Part-ARO?

Can we integrate the processes for a permission under Part-SERA and with high-risk authorisation (HRA) under Part-ARO?

Can I carry out ‘limited operations’ with aircraft having FC/PtF for NCO ?

Does Regulation (EU) No 965/2012 also apply to third-country operators that conduct specialised operations in an EU Member State?

Helicopter operations

Do additional equipment for HEC (ropes, harnesses) now require an airworthiness approval?

How do I train the pilots if I plan to operate HEC with a video camera and no mirrors / bubble window?

Which standards are applicable to Helicopter terrain awareness systems (HTAWS)?

Special Categories of Passengers (SCPs)

Who is an SCP?

I am tall or have other circumstances. Do I belong to the group of SCPs?