Air transport: compliance checklist
Use this checklist to confirm your air transport business (SIC division 51) meets its obligations before you begin …
Air transport is one of the most heavily licensed sectors in the UK. This guide takes you through operating licences, air operator certificates, airworthiness and crew licensing, ATOL protection, passenger rights, dangerous goods by air, and — if you conduct spaceflight — operator licences, spaceport licences and third-party liability insurance. The Civil Aviation Authority regulates all of it UK-wide.
Use this checklist to confirm your air transport business (SIC division 51) meets its obligations before you begin …
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Aviation and spaceflight licensing sits under the Civil Aviation Authority (CAA), the single UK-wide regulator. The aviation regime rests on the Civil Aviation Act 1982 and the Air Navigation Order 2016; spaceflight has its own statutory regime under the Space Industry Act 2018 — the AOC and Air Navigation Order do not apply to spaceflight. Work through the sections below in order; not every section will apply to every operator.
If you operate as a UK air carrier — passenger or freight — you must hold a CAA operating licence demonstrating adequate financial standing, a UK principal place of business and mandatory aviation insurance. Passenger carriers need a Type A licence (20 or more seats) or Type B (smaller aircraft); freight carriers need the equivalent cargo licence. The regime derives from retained Regulation (EC) No 1008/2008, given effect alongside the Civil Aviation Act 1982.
On top of the operating licence, you must hold an AOC demonstrating that you can conduct flight operations safely. The AOC sets out your approved aircraft types, routes and operating procedures and is subject to continuing CAA oversight and audit under the Air Navigation Order 2016 and the Civil Aviation Act 1982. Passenger and freight operations each require their own AOC.
Each aircraft you operate must hold a valid certificate of airworthiness and be maintained under an approved continuing-airworthiness regime. Flight crew must hold current CAA pilot licences, ratings and medical certificates. These requirements apply to both passenger and freight operations under the Air Navigation Order 2016.
If you sell or arrange flight-inclusive package holidays or flight-only deals to consumers, you generally need an Air Travel Organiser's Licence (ATOL) from the CAA. ATOL protects customers if the business fails. A pure scheduled airline selling its own seats is generally exempt, but a carrier acting as a package organiser needs an ATOL. The regime sits under the Civil Aviation (Air Travel Organisers' Licensing) Regulations 2012, the Air Travel Organisers' Licensing Act 2017 and the Civil Aviation Act 1982.
If you carry passengers by air, you must comply with UK261 (retained Regulation (EC) No 261/2004) — you must compensate and assist passengers for denied boarding, cancellation and long delay, and provide care such as meals and accommodation. The CAA enforces these rights, with alternative dispute resolution via an approved ADR body. This applies UK-wide.
If you carry dangerous goods by air, specific training, packaging and documentation requirements apply. Staff involved in accepting, handling or loading dangerous goods must hold current IATA Dangerous Goods Regulations (DGR) training, renewed every 24 months. Packaging must be UN-certified (tested by the VCA Dangerous Goods Office on behalf of the Department for Transport), and a Shipper's Declaration of Dangerous Goods is required.
If you carry out spaceflight activities from the UK — launch, return or operating a launch vehicle — you need an operator licence from the CAA under the Space Industry Act 2018 and the Space Industry Regulations 2021, with a safety case, security arrangements and mandatory liability cover. The AOC and Air Navigation Order regime does not apply to spaceflight.
If you operate a spaceport or provide range-control services, you need a separate CAA licence under the Space Industry Act 2018, covering site safety, range safety and environmental assessment.
If you hold a spaceflight licence, you must hold mandatory third-party liability insurance to a level set by the CAA in the licence. The Space Industry Act 2018 framework allocates and caps liability for injury or damage caused by spaceflight activities.
Apply to the CAA for your operating licence (Type A or B for passenger; freight equivalent for cargo), demonstrating financial standing, a UK principal place of business and mandatory aviation insurance.
Apply to the CAA for your AOC, setting out your approved aircraft types, routes and operating procedures.
Confirm each aircraft holds a valid certificate of airworthiness, is maintained under an approved regime, and all flight crew hold current CAA licences, ratings and medicals.
If you sell or arrange flight-inclusive packages or flight-only deals to consumers, apply to the CAA for an ATOL.
Put UK261 compensation, care and assistance procedures in place for passenger operations, and ensure IATA DGR training, UN-certified packaging and documentation for any dangerous goods by air.
If you conduct spaceflight activities, apply for a CAA operator licence and, if you operate a spaceport, a separate spaceport/range licence, and arrange the mandatory third-party liability insurance.
With your safe-operation spine and the aviation and spaceflight licences in place, confirm the whole picture with the air transport compliance checklist. If you are not sure which guides apply to you, start from the router.
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