You really don't need an AOC, only a GA operator
Most operators and management companies are advertising benefits of flying under an Air Operator Certificate (AOC), but reality is that for private/corporate flying it's more of an obstacle than an advantange. Unless you need actual commercial flights (selling charters), you would be putting severe restrictions on your operation and freedom of controlling your asset (aircraft).
Also, for these perceived benefits to actually apply, flight must be declared commercial, which "turns on" all the restrictions. For example, you can't fly without obtaining a permit (where it's applicable) by declaring a flight as non-commercial to avoid it, and then buy fuel as if you are flying a commercial flight under an AOC. You can't buy fuel without any taxes (where it's applicable) based on the mere fact that the aircraft is on the AOC, while the flight is non-commercial.
To avoid basic restrictions, the flight would have to be declared as non-commercial, which is not even possible under some AOCs, and in this case, getting any of the percieved benefits (like fuel price) is impossible and even illegal.
Bottom line, you can't have all the benefits without any restrictions legally, no matter what is advertised.
They all want you under an AOC, but it's not easy or fast to exit it.
On the other hand, it doesn't mean one can operate a jet without any framework. There must be an operator with established procedures, training, flight and ground operations support capability, etc. Tinadar Jets is such an operator - a General Aviation (GA) operator with all the approvals like RVSM, PBN, etc. Essentially, it's like an AOC, but without all the bad stuff. It gives the same level of safety, without all the restrictions while also retaining a lot of freedom to control your asset, less the commercial element.
Please check the list below for major elements in detail...
Also, for these perceived benefits to actually apply, flight must be declared commercial, which "turns on" all the restrictions. For example, you can't fly without obtaining a permit (where it's applicable) by declaring a flight as non-commercial to avoid it, and then buy fuel as if you are flying a commercial flight under an AOC. You can't buy fuel without any taxes (where it's applicable) based on the mere fact that the aircraft is on the AOC, while the flight is non-commercial.
To avoid basic restrictions, the flight would have to be declared as non-commercial, which is not even possible under some AOCs, and in this case, getting any of the percieved benefits (like fuel price) is impossible and even illegal.
Bottom line, you can't have all the benefits without any restrictions legally, no matter what is advertised.
They all want you under an AOC, but it's not easy or fast to exit it.
On the other hand, it doesn't mean one can operate a jet without any framework. There must be an operator with established procedures, training, flight and ground operations support capability, etc. Tinadar Jets is such an operator - a General Aviation (GA) operator with all the approvals like RVSM, PBN, etc. Essentially, it's like an AOC, but without all the bad stuff. It gives the same level of safety, without all the restrictions while also retaining a lot of freedom to control your asset, less the commercial element.
Please check the list below for major elements in detail...
Overfly and Landing Permits
General Aviation (GA)
Most countries do not require permits for private/corporate flights to overfly or land in their territory. Even if one is required, it's usually much easier and faster to obtain than for a commercial flight.
Private/corporate flights within any country (like Frankfurt to Berlin) are generally allowed.
Private/corporate flights within any country (like Frankfurt to Berlin) are generally allowed.
Air Operator Certificate (AOC)
Most countries in the world require a permit to be obtained for a commercial flight to overfly or land in their territory. It's usually impossible to obtain such a permit on weekends or holidays or even the same day.
There are just a few exceptions to this general rule in the world. For example, an EU AOC holder can commercially fly to (and within) other EU countries without obtaining a permit. Though, outside of the EU, all AOC holders would be in the same position.
Outside EU, the so called cabotage is forbidden - AOC holders can't carry passengers within a country (except AOC holders within their own country).
There are just a few exceptions to this general rule in the world. For example, an EU AOC holder can commercially fly to (and within) other EU countries without obtaining a permit. Though, outside of the EU, all AOC holders would be in the same position.
Outside EU, the so called cabotage is forbidden - AOC holders can't carry passengers within a country (except AOC holders within their own country).
FLEXIBILITY AND PREDICTABILITY
GA
Maximum flexibility. You retain the ability to control the situation to a very large degree.
Only operational approvals (like RVSM, PBN, LVTO, etc.) require authority's direct involvement, and is typically done much faster, as even though requirements are largely the same to keep the same level of safety (training, procedures, etc.).
Enrolling new pilots also require largely the same amount of training for the OCC to achieve the same level of safety, but the process itself is much more flexible and adjustments can be made along the way to accomodate operational needs, while remaining safe and compliant. Line training process is much more flexible, and flight operations manager can make decisions based on common sense, instead of on a rigid set of orders from the AMC documents and its reflection in the Operating Manual.
In general, regulatory requirements are much lighter, akin to those for AOC holders many years ago, where main difference is that an operator could decide what is best for its scale and type of operation instead of current situation, where authorities blindly apply same rules to an AOC holder flying business jets in a range of different situations as for AOC holder flying scheduled flights on large transport airliners with a large, but permanent route network.
It is also much easier to exit from a GA operator than leaving an AOC holder's grip.
Only operational approvals (like RVSM, PBN, LVTO, etc.) require authority's direct involvement, and is typically done much faster, as even though requirements are largely the same to keep the same level of safety (training, procedures, etc.).
Enrolling new pilots also require largely the same amount of training for the OCC to achieve the same level of safety, but the process itself is much more flexible and adjustments can be made along the way to accomodate operational needs, while remaining safe and compliant. Line training process is much more flexible, and flight operations manager can make decisions based on common sense, instead of on a rigid set of orders from the AMC documents and its reflection in the Operating Manual.
In general, regulatory requirements are much lighter, akin to those for AOC holders many years ago, where main difference is that an operator could decide what is best for its scale and type of operation instead of current situation, where authorities blindly apply same rules to an AOC holder flying business jets in a range of different situations as for AOC holder flying scheduled flights on large transport airliners with a large, but permanent route network.
It is also much easier to exit from a GA operator than leaving an AOC holder's grip.
AOC
Zero flexibility. The only predictibility is that there's no predictibility. Anything under AOC will be complicated and generally slow - in case changes are needed other than flying according to established structure (procedures, pilots, approvals, etc.).
No matter how good relations are between AOC holder and aviation authority, regulation itself is very rigid as regulation can't actually be interpreted - there is a document called Acceptable Means of Compliance (AMC) and that's the only practical option to comply as considered by the authority.
Making changes to procedures, getting operational approvals, including things needed to fly to airports requiring special approval is possible, but requires substantial resources and time, hence expenses and possibly cancelled plans due to unpredictable issues with the authority along the way.
Enrolling new pilots is a separate lenghy process, starting from the Operator Conversion Course (OCC) (consisting of many elements) to the completion of the Line Training, which requires a Line Training Captain (LTC), a Line Check Captain (two separate people), and ground instructors. Whole process is very rigid and typically takes at least 2 weeks even until start of flying, and up to a couple of months until the release (when a pilot can fly without an LTC).
It would be totally fine for an airline with one large type, a dozen aircraft, known route network and schedule, but not for an AOC holder working with business jets, typically each aircraft being a unique type and no schedule whatsoever.
They say it's all for safety, but in reality, operator becomes bloated - much more people are necessary to support the level of bureaucracy - higher chance of mistakes, and hence people are much more focused on compliance (for things to look good on paper) rather than on the actualy safety.
No matter how good relations are between AOC holder and aviation authority, regulation itself is very rigid as regulation can't actually be interpreted - there is a document called Acceptable Means of Compliance (AMC) and that's the only practical option to comply as considered by the authority.
Making changes to procedures, getting operational approvals, including things needed to fly to airports requiring special approval is possible, but requires substantial resources and time, hence expenses and possibly cancelled plans due to unpredictable issues with the authority along the way.
Enrolling new pilots is a separate lenghy process, starting from the Operator Conversion Course (OCC) (consisting of many elements) to the completion of the Line Training, which requires a Line Training Captain (LTC), a Line Check Captain (two separate people), and ground instructors. Whole process is very rigid and typically takes at least 2 weeks even until start of flying, and up to a couple of months until the release (when a pilot can fly without an LTC).
It would be totally fine for an airline with one large type, a dozen aircraft, known route network and schedule, but not for an AOC holder working with business jets, typically each aircraft being a unique type and no schedule whatsoever.
They say it's all for safety, but in reality, operator becomes bloated - much more people are necessary to support the level of bureaucracy - higher chance of mistakes, and hence people are much more focused on compliance (for things to look good on paper) rather than on the actualy safety.
YOUR PRIVACY
GA
Most countries do not require advanced passenger information for private/corporate flights (less some notable exceptions like the US of course). In general, legally, much less information is disclosed in a private/corporate operator.
AOC
No privacy. AOC holders are obliged to pass all passenger information (and a lot of other information) to authorities of origin/departure country for every flight in advance.
YOUR SAFETY
GA
With an honest and professional operator, you would see at least the same level of safety as with a frequently audited AOC holder for a fraction of the cost. Most experienced people went to work for GA operators after taking the pleasure and health to work in modern AOC envrionment - these people are acutely aware of what actual safety should look like.
GA operator is able to focus on the actual safety - development of effective procedures, actual training, making sure equipment is compliant, etc. We are able to take good things and practice from AOC holders, and skip most of the bureaucracy. We retain the ability to choose what is best.
GA operators still get to be audited, and SAFA inspection is the same as for commercial flights to make sure we are focused.
Even though, GA regulatory environment allows to "skip corners", it is key to work with a GA operator with experience and true Safety Culture (not one made of paper).
GA operator is able to focus on the actual safety - development of effective procedures, actual training, making sure equipment is compliant, etc. We are able to take good things and practice from AOC holders, and skip most of the bureaucracy. We retain the ability to choose what is best.
GA operators still get to be audited, and SAFA inspection is the same as for commercial flights to make sure we are focused.
Even though, GA regulatory environment allows to "skip corners", it is key to work with a GA operator with experience and true Safety Culture (not one made of paper).
AOC
Safety level is perceived to be good, but due to a lot of bureaucracy in AOC holder's life, focus is almost always on doing papers right, not safety itself. Even though CAA auditors are asking for postholders to know their stuff, in the end it boils down to a proof that something was done only on a paper (or an electronic equivalent). That obviously does not apply to big airlines, where level of safety is very high as they have resources to achieve it.
One thing is true, training in AOC environment is generally good, if done right (that is, in large scheduled airlines), but given the rigidity of the process, rigidity of requirements, and amount of paper trail required, smaller operators often skip a lot of actual training and make it as formal as possible, as it's quite expensive to do both - good on paper and good in reality.
One thing is true, training in AOC environment is generally good, if done right (that is, in large scheduled airlines), but given the rigidity of the process, rigidity of requirements, and amount of paper trail required, smaller operators often skip a lot of actual training and make it as formal as possible, as it's quite expensive to do both - good on paper and good in reality.
COSTS
GA
Overall costs for an operator are generally less than those flying under an AOC. It's due to the fact that outside places like the EU, prices for ground handling, navigation and fuel are generally the same (for GA and AOC operators), but fixed costs of supporting the AOC are much larger in any case.
Flying under an AOC is akin to spinning a flywheel. Once started, it's very hard to stop, it will go on and on (fixed costs, including crew and supporting the regulatory compliance). With a GA operator you have less fixed costs, we can optimize.
VAT is generally not applicable due to the fact that flights are international and operator is from outside the EU, with a VAT number, though, it should be noted that some EU countries do not adhere to their own laws in this regard.
Also, with a GA operator, you get to choose a better solution as you retain flexibility.
Flying under an AOC is akin to spinning a flywheel. Once started, it's very hard to stop, it will go on and on (fixed costs, including crew and supporting the regulatory compliance). With a GA operator you have less fixed costs, we can optimize.
VAT is generally not applicable due to the fact that flights are international and operator is from outside the EU, with a VAT number, though, it should be noted that some EU countries do not adhere to their own laws in this regard.
Also, with a GA operator, you get to choose a better solution as you retain flexibility.
AOC
Regulatory requirements are increasing day by day nowadays and compliance becomes the main duty of AOC holders as opposed to actual flying. It may be laughable, but it's the truth. So, expences to support that monster are increasing day by day.
It's double the amount of training as it would be for a GA operator. And not in terms of coverage, which is the same, but frequency. AOC holders' pilots get to train in the simulator every 6 months. It's not a bad thing in itself, but imagine the logistics (hence expenses) required to do that for a business jet operator (where simulators are usually scarse, not close by and there aren't too many pilots to spare) in comparison to a scheduled airline (where simulators are close and abundant) for which these requirements are actually meant. Single recurrent for a mid-size business jet cost is around 30-40k USD per pilot. All that for a very questionable benefit (6 months instead of 12). Doctors don't get any training at all other than being required to attend some conferences and seminars, yet they treat people every day.
Fuel costs are reduced, but only in places like the EU. AOC holders get to skip Mineral and Oil Tax (MOT) and VAT. But MOT doesn't exist outside the EU, and VAT is almost always not applicable anyway on international flights for a third-country operator.
If you are mostly flying outside the EU, percieved fuel cost benefit is zero as prices are the same anyway. Though, if you fly within the EU, all the benefits are 100% offset by the additional expenses and total lack of flexibility in all other areas of operation under an AOC. Fuel cost benefit only actually makes sense if you fly a lot (600+ hours annually) and largely only within the EU, but you would still be lacking flexibility and freedom.
It's double the amount of training as it would be for a GA operator. And not in terms of coverage, which is the same, but frequency. AOC holders' pilots get to train in the simulator every 6 months. It's not a bad thing in itself, but imagine the logistics (hence expenses) required to do that for a business jet operator (where simulators are usually scarse, not close by and there aren't too many pilots to spare) in comparison to a scheduled airline (where simulators are close and abundant) for which these requirements are actually meant. Single recurrent for a mid-size business jet cost is around 30-40k USD per pilot. All that for a very questionable benefit (6 months instead of 12). Doctors don't get any training at all other than being required to attend some conferences and seminars, yet they treat people every day.
Fuel costs are reduced, but only in places like the EU. AOC holders get to skip Mineral and Oil Tax (MOT) and VAT. But MOT doesn't exist outside the EU, and VAT is almost always not applicable anyway on international flights for a third-country operator.
If you are mostly flying outside the EU, percieved fuel cost benefit is zero as prices are the same anyway. Though, if you fly within the EU, all the benefits are 100% offset by the additional expenses and total lack of flexibility in all other areas of operation under an AOC. Fuel cost benefit only actually makes sense if you fly a lot (600+ hours annually) and largely only within the EU, but you would still be lacking flexibility and freedom.
TAXES
GA
Aircraft import is legally much more flexible. You wouldn't be obliged to import it into AOC holder's country, it would generally depend on the base of the owner and the aircraft. Large chunks can be completely legally optimized to be the same as for an AOC holder (closer to zero) in terms of import taxes, but it's all decided on a case by case basis. Import customs duty is the same as for an AOC holder anyway, only the VAT may be applicable.
For operation (cost of ground handling, fuel, etc.), VAT is generally not applicable on the basis of basic VAT laws (except, for example, for flights within a single country, in which case, VAT would also be applicable to an AOC holder doing a ferry or legal cabotage in case of an EU AOC holder).
Mineral and Oil Tax (MOT) will always be applicable for non-commercial flights, but it only exists in some countries for now.
For operation (cost of ground handling, fuel, etc.), VAT is generally not applicable on the basis of basic VAT laws (except, for example, for flights within a single country, in which case, VAT would also be applicable to an AOC holder doing a ferry or legal cabotage in case of an EU AOC holder).
Mineral and Oil Tax (MOT) will always be applicable for non-commercial flights, but it only exists in some countries for now.
AOC
Import duty (as opposed to VAT) needs to be paid for import of an aircraft in any case, and in many countries it's not zero even for AOC holders. VAT is almost always zero if an aircraft is to be used for commercial flights. But European authorities plan to implement controls in order to make sure imported aircraft are actually used for commercial flights, and not private/corporate-only travel.
In order to benefit from tax-free fuel for commercial flights, in some countries (flight destinations), operator needs to go through complex procedures to be approved, some times even for every flight. Managing it is quite complex and governments obviously manage it in their interest even though, you would think you are 100% eligible.
For an AOC holder, aircraft must be imported in the country of the AOC holder. When an aircraft is taken out of the AOC, it needs to be re-exported. So, it's not easy to change home for an aircraft without risks.
In order to benefit from tax-free fuel for commercial flights, in some countries (flight destinations), operator needs to go through complex procedures to be approved, some times even for every flight. Managing it is quite complex and governments obviously manage it in their interest even though, you would think you are 100% eligible.
For an AOC holder, aircraft must be imported in the country of the AOC holder. When an aircraft is taken out of the AOC, it needs to be re-exported. So, it's not easy to change home for an aircraft without risks.
COMMERCIAL FLIGHTS
GA
Commercial flights (transport of passengers, cargo or mail for renumeration) are not possible, but it only applies to sales to third parties. For example, payments between related corporate entities (one of which would be the owner) for direct operating cost recovery is quite normal.
If aircraft has several owners, any owner can fly without limitations and make the necessary payments for the operating costs.
In some registries, an aircraft itself can be leased for a longterm exclusive use for renumeration (so called "charter by demise").
If aircraft has several owners, any owner can fly without limitations and make the necessary payments for the operating costs.
In some registries, an aircraft itself can be leased for a longterm exclusive use for renumeration (so called "charter by demise").
AOC
Commercial flights are possible.
Cabotage (flight within a single country) is not possible, with some exceptions (like for an EU operator flying only within the EU).
Cabotage (flight within a single country) is not possible, with some exceptions (like for an EU operator flying only within the EU).
- Oleksandr KonovalovTinadar Jets - Safety and Compliance, Training ManagerIt's not an Air Operator Certificate that makes your operations safe and reliable, rather it is people in charge 😉
