Non-commercial operations with complex NCC aircraft

    Operators engaged in non-commercial operations with complex powered aircraft in accordance with Article 5(3) of Commission Regulation (EU) 965/2012 of 5 October 2012 must submit the corresponding declaration of compliance (requirement ORO.DEC.100) with the applicable requirements of Annexes III (Part-ORO) and VI (Part-NCC).

    In the case of specialised non-commercial operations, the declaration of compliance shall refer to compliance with Annexes III (Part-ORO) and VIII (Part-SPO).

    In addition to the requirements set out in the Regulation, the European Aviation Safety Agency (EASA) has published by Decision of the Executive Director of EASA the Acceptable Means of Compliance (AMC) and the Guide Material (GM).

    An unofficial translation of the acceptable means of compliance and guidance material to Annexes III (Part-ORO) and VI (Part NCC) to Regulation (EU) 965/2012 is provided below:

    In addition to the declaration of compliance with the applicable requirements, a minimum list of equipment approved (MEL) by the State Aviation Safety Agency in accordance with requirement ORO.MLR.105 is required to perform this type of operation and to develop an Operations Manual in accordance with the structure indicated in the AMC2 ORO.MLR.100 in which the procedures to be applied by the operator are developed.

    The operator must also inform the State Aviation Safety Agency of the cessation of its operations.

    Submission of the declaration in case of non-commercial operations with complex aircraft

    IMPORTANT: The declaration must be submitted by the operator of the aircraft(s). In this respect there are two possibilities:

    • The owner of the aircraft(s) is in turn the operator of the aircraft(s). In this case the Responsible Director appointed under ORO.GEN.210 must sign the declaration. The necessary approvals (MEL, special approvals) will be issued on behalf of the owner/operator.
    • The owner of the aircraft(s) may hire a third party to operate the aircraft(s), as indicated in GM1 ORO.DEC.100. The Responsible Director of the organisation contracted by the owner must sign the declaration. Prior to the submission of the declaration, the contract signed between the owner and the organisation that will operate the aircraft must be submitted to the Directorate of Civil Aviation Safety and User Protection (DSACPU) of the State Aviation Safety Agency.

    The necessary approvals (MEL, special approvals) must be requested by the contracted organisation to carry out the operation and issued in the name of the operation.

    The State Aviation Safety Agency has made available to operators a portal in which they can complete and submit the above-mentioned declaration in two different ways:

    • With electronic certificate: In the case of opting for this route, 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.
    • No electronic certificate. 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 the provisions of Article 38 of Law 30/1992 of 26 November 1992 on the Legal Regime of Public Administrations and the Common Administrative Procedure.

    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 non-commercial operations.

    At the State Aviation Safety Agency’s website you will find a user manual to use the application.

    Resolutions of the State Aviation Safety Agency

    Informative triptychs and safety promotion material


    For inquiries concerning non-commercial operations with complex motor-powered aircraft, please contact the mailbox

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