Procedure for enabling yourself as an operator to conduct specialised commercial operations

    From 21 April 2016 those aeroplane and helicopter operators wishing to conduct specialised operations on a commercial basis, to date known as aerial work, shall comply with the requirements laid down in Commission Regulation (EU) 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) 216/2008 of the European Parliament and of the Council, hereinafter referred to as Regulation (EU) 965/2012.

    In particular, Article 5(6) of Regulation (EU) 965/2012 provides that operators may only operate an aircraft for specialised commercial operations in compliance with Annex III (Part-ORO) and Annex VIII (SPO), which set out the requirements to be met by the operator as an organisation and the specific requirements for the operation and equipment of aircraft engaged in such operations respectively.

    Notwithstanding the above, specialised operations carried out with aircraft meeting the criteria set out in Annex II to Regulation (EC) No 216/2008 shall not be covered by Regulation (EU) 965/2012, in any case the national legislation being applied.

    Likewise, and until 21 April 2017 Regulation (EU) 965/2012 will not apply to specialised operations carried out with balloons and sailplanes pursuant to the Resolution of 16 February 2016 of the Directorate of the State Aviation Safety Agency.

    Procedure for enabling yourself as an operator to conduct specialised commercial operations

    With the entry into force of Regulation (EU) 965/2012 of 5 October 2012, the procedure applicable to an air operator to qualify for specialised commercial operations varies substantially.

    In accordance with the ORO.DEC.100 requirement, operators wishing to engage in specialised commercial operations must submit a declaration containing all relevant information before the start of operations. Any changes to the information contained in the declaration must also be notified to the State Aviation Safety Agency.

    To this end, the State Aviation Safety Agency makes available to operators an access portal in which they can submit the above declaration in two different ways:

    • With electronic certificate: The Responsible Director of the operator must, once the declaration has been completed on the AESA website, sign it with its electronic certificate. Once the system has been signed, the document will be returned to you for the submission of the declaration to the EASA Telematic Register. In compliance with the provisions of Article 14(2) of Law 39/2015 of 1 October 2015, legal persons, entities without legal personality and those engaged in a professional activity for which compulsory membership is required must submit the declaration using this route. In the case of natural persons this means shall be optional.
    • No electronic certificate. This route is only available to natural persons. In this case the declaration will be generated in.pdf format from the AESA website. Once the declaration has been completed, it must be printed, signed by the Responsible Director and presented in the EASA Register or in accordance with Article 16(4) of Law 39/2015 of 1 October 2015.


    Important: It must provide two copies of the declaration, one of which shall be for EASA and the other shall be kept by the operator as proof of its submission.

    Once the declaration has been submitted, the operator shall be entitled to carry out specialised commercial operations that are not of high risk. For the latter, in addition to the declaration, the operator must obtain the authorisation provided for in ORO.SPO.110.

    Any changes to the information contained in the declaration shall be communicated to EASA by submitting a new declaration.

    The operator must also inform AESA of the cessation of its operations.

    Through the following link you can access the application to submit/generate the declaration provided for in ORO.DEC.100:

    Link to Responsible Statement at EASA’s Electronic Headquarters

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