EASA Air Operations: Rules, AOC and Duties
EASA air operations under Regulation (EU) No 965/2012: the Part-CAT structure, when an operator needs an AOC, and the operator’s core responsibilities.
Dionysis Kefalas6 min readFor Air Ops staff
Part 1 of 6 in EASA Air Operations Show parts
Quotes checked on against EASA Easy Access Rules for Air Operations (Regulation (EU) No 965/2012) — 27 Mar 2026 revision.
On this page
What the air operations rules are
The working copy on an operations desk is the EASA Easy Access Rules for Air Operations: Regulation (EU) No 965/2012 consolidated with its Acceptable Means of Compliance and Guidance Material. The regulation itself is a short cover regulation — the numbered Articles — followed by Annexes. The 2026-03-27 table of contents labels those Annexes as follows.
Part-ORO opens by naming the operations its organisation rules apply to.
This Annex establishes the requirements to be met by an air operator that conducts:
(a)commercial air transport (CAT) operations;
(b)commercial specialised operations;
(c)non-commercial operations with complex motor-powered aircraft;
(d)non-commercial specialised operations with complex motor-powered aircraft;
(e)innovative air mobility (IAM) operations.
Quoted word for word from Regulation (EU) No 965/2012, Easy Access Rules for Air Operations, 27 Mar 2026 revision.
This series stays on (a): commercial air transport, and the AOC that goes with it. Points (b) to (e), and Annexes VI, VII and VIII, are outside these guides.
Commercial air transport and the AOC
CAT operations with an aeroplane or a helicopter are not described in Part-ORO alone. Article 5 says where they are specified, and it limits the operator to that specification.
1.Operators shall only operate an aeroplane or a helicopter for the purpose of commercial air transport (hereinafter “CAT”) operations as specified in Annexes III and IV.
Quoted word for word from Regulation (EU) No 965/2012, Easy Access Rules for Air Operations, 27 Mar 2026 revision.
The certificate comes before the operation. ORO.AOC.100(a) is the line that puts the AOC in front of the first CAT flight.
(a)Without prejudice to Regulation (EC) No 1008/2008 of the European Parliament and of the Council, prior to commencing CAT operations with aeroplanes or helicopters or IAM operations with VCA, the operator shall apply for and obtain an AOC issued by the competent authority.
[…]
(c)Applicants shall demonstrate to the competent authority that:
(1)the CAT operations with aeroplanes and helicopters comply with the essential requirements of Annex V to Regulation (EU) 2018/1139, this Annex (Part-ORO), Annex IV (Part-CAT) and Annex V (Part-SPA) to this Regulation, and Annex I (Part-26) to Regulation (EU) 2015/640;
[…]
(3)their organisation and management is suitable and properly matched to the scale and scope of the intended operation.
Quoted word for word from Regulation (EU) No 965/2012, Easy Access Rules for Air Operations, 27 Mar 2026 revision.
Paragraph (a) is the gate before the first CAT or IAM flight. What the applicant has to demonstrate is (c), including the scale-and-scope test in (c)(3). How that application is built is the next guide, How to Get an EASA Air Operator Certificate (AOC).
What the operator is responsible for
An AOC does not move the operation onto someone else. ORO.GEN.110 is the point that lists what the operator is responsible for.
(a)The operator is responsible for the operation of the aircraft in accordance with Annex IV to Regulation (EC) No 216/2008, as applicable, the relevant requirements of this Annex and its air operator certificate (AOC) or specialised operation authorisation (SPO authorisation) or declaration.
(b)Every flight shall be conducted in accordance with the provisions of the operations manual.
(c)The operator shall establish and maintain a system for exercising operational control over any flight operated under the terms of its certificate, SPO authorisation or declaration.
(d)The operator shall ensure that its aircraft are equipped and its crews are qualified as required for the area and type of operation.
[…]
Quoted word for word from Regulation (EU) No 965/2012, Easy Access Rules for Air Operations, 27 Mar 2026 revision.
Paragraph (b) is why the manual is the instruction set for the flight, and (c) is the operational-control system. Both are taken up in The Operations Manual and Management System under Part-ORO.
How responsibility reaches the cockpit
The operator holds the organisational responsibility. On the aircraft, CAT.GEN.MPA.100 names the crew member and CAT.GEN.MPA.105 names the commander.
(a)The crew member shall be responsible for the proper execution of his or her duties that are:
(1)related to the safety of the aircraft and its occupants; and
(2)specified in the instructions and procedures in the operations manual.
[…]
Quoted word for word from Regulation (EU) No 965/2012, Easy Access Rules for Air Operations, 27 Mar 2026 revision.
(a)The commander, in addition to complying with CAT.GEN.MPA.100, shall:
(1)be responsible for the safety of all crew members, passengers and cargo on board, as soon as the commander arrives on board the aircraft, until the commander leaves the aircraft at the end of the flight;
(2)be responsible for the operation and safety of the aircraft:
(i)for aeroplanes, from the moment the aeroplane is first ready to move for the purpose of taxiing prior to take-off, until the moment it finally comes to rest at the end of the flight and the engine(s) used as primary propulsion unit(s) is(are) shut down;
(ii)for helicopters, when the rotors are turning;
(3)have authority to give all commands and take any appropriate actions for the purpose of securing the safety of the aircraft and of persons and/or property carried therein in accordance with point 7.2 of Annex V to Regulation (EU) 2018/1139;
[…]
(8)ensure that all operational procedures and checklists are complied with in accordance with the operations manual;
[…]
(11)decide on acceptance of the aircraft with unserviceabilities in accordance with the configuration deviation list (CDL) or the minimum equipment list (MEL);
Quoted word for word from Regulation (EU) No 965/2012, Easy Access Rules for Air Operations, 27 Mar 2026 revision.
The crew member's duties are (a)(1) and (a)(2). For the commander, the safety responsibility and the aeroplane's operating window are (a)(1) and (a)(2); the authority to give commands is (a)(3). Checklists and acceptance of an unserviceable aircraft are (a)(8) and (a)(11). The gaps above are other commander duties this page does not walk through.
Crew qualification, and the limits on how long a crew member may be on duty, are a separate guide: EASA Flight Time Limitations (FTL) and Crew Requirements.
Extending what the AOC lets you do
Some operations sit in Annex V, Part-SPA. Part five of this series, EASA Specific Approvals (Part-SPA): LVO, PBN, ETOPS and More, quotes the common application, recording and validity rules, and one worked approval.
Where to read it yourself
The EASA Easy Access Rules for Air Operations is a free download from the EASA website. The 2026-03-27 revision is the version every citation in this guide was checked against.
This is the first guide in the air operations series. Part two builds and holds the AOC. Part three is the operations manual and the Part-ORO management system. Part four is crew composition and flight time limitations. Part five is Part-SPA. Part six is ramp inspection findings and the operator's reply.
Educational content, not regulatory compliance advice. Verify against the current regulation text before relying on it.
In this series
Related
- How to Get an EASA Air Operator Certificate (AOC)Guide · 7 min
- The Operations Manual and Management System under Part-OROGuide · 5 min
- EASA Flight Time Limitations (FTL) and Crew RequirementsGuide · 14 min
- EASA Specific Approvals (Part-SPA): LVO, PBN, ETOPS and MoreGuide · 5 min
- SAFA Ramp Inspection Findings: Cat 1, 2, 3 and Your ReplyGuide · 16 min
Written by Dionysis Kefalas. Retired Hellenic Air Force Captain and founder of Avioverse. About the author
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