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30th November 2020


We have 22 working days until the end of the Brexit Transition Period, with an agreement looking less likely.

As a reminder to our Member Briefing of two weeks ago we’re urging all our UK AOC holder members to urgently reach out to the Aviation Authorities of the EU member states, to understand what they need to do specifically to continue to operate commercial flights after the 1st January 2021.

As an example, we refer you to the Spanish AIP which requires Third Country commercial operators flying into Spanish territory more than three times in each IATA Summer and Winter season (in business aviation this might not be as widely understood, but essentially the six month period March-October) to hold an Accreditation from the Spanish State Agency for Air Safety.  To clarify, this is an additional requirement from Spain and unrelated to the EASA Third Country Operator approval. If you hold the EASA TCO it does not remove the requirement to hold this separate Spanish approval.

This approval can take up to 1 MONTH to obtain, i.e. the last date for application would be 1st December 2020.

As of last week, the UK DfT informs us that the Spanish authorities have received NO applications from UK Non-Scheduled AOC holders for this approval and you are urgently advised to check if it applies to your operation.

Currently, we are aware of a similar requirement in Poland but it is taking time to collate this information.  In Ireland, the EASA TCO is accepted on its own, however a permit will need to be obtained for any non-scheduled AOC operations. The lead time for this is 48 hours, meaning that go-now operations are likely to be severely curtailed.

We sincerely hope that within the next 22 working days, there is a light bulb moment in the negotiations and some more practical approach is agreed. However, we strongly urge you as UK AOC Holders, if you wish to operate into EU Member States after 1st January 2021, to ensure you have researched everything you need to know about the requirements for Third Country Operator operations in the specific countries you visit.

We are holding a roundtable meeting with the UK DfT and UK CAA for our AOC Holding Members from the EU and UK, the 10th December at 1600 UTC.  If you are an AOC holder and wish to be included on the attendee list, but have not already informed us, please email urgently.

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