ACMI Wet Lease Requirements: A Practical Guide for Aircraft Operators
Everything you need to know about ACMI wet-lease regulatory requirements — EASA compliance, insurance minimums, operational approvals, and documentation.
ACMI Wet Lease Requirements: A Practical Guide for Aircraft Operators
ACMI (Aircraft, Crew, Maintenance, Insurance) wet leasing is the backbone of seasonal capacity management for airlines worldwide. But the regulatory landscape is complex, and non-compliance can ground your operation.
This guide walks through every requirement you need to satisfy before an ACMI transfer.
What Is an ACMI Wet Lease?
An ACMI wet lease is an operational lease where the lessor provides:
- Aircraft (the physical airframe and engines)
- Crew (certified flight deck and cabin crew)
- Maintenance (line and base maintenance coverage)
- Insurance (liability and hull coverage)
The lessee operates the aircraft under their own AOC, using the lessor's crew and maintenance infrastructure.
Regulatory Framework
EASA Requirements
Under EASA regulations, the leasing operator (lessee) carries operational responsibility. This means:
1. The lessee's AOC must cover the aircraft type
2. The aircraft must meet the lessee's operational specifications
3. EASA must be notified of the lease arrangement (OPS 1.165)
4. The lessee must verify the lessor's documentation
EU 785/2004 Insurance Compliance
Insurance is the most commonly overlooked compliance gap. EU Regulation 785/2004 mandates minimum coverage:
Third-Party Liability by MTOW:
Aircraft under 500 kg: 750,000 SDR minimum
500–2,700 kg: 1.5M SDR
2,700–6,000 kg: 3M SDR
6,000–20,000 kg: 8M SDR
20,000–50,000 kg: 18M SDR
50,000–200,000 kg: 98M SDR
Over 200,000 kg: 180M SDR
Passenger Liability: 250,000 SDR per passenger (minimum)
The MTOW-based calculation must use the aircraft's certified maximum take-off weight, not the operating weight.
Required Documentation
From the Lessor
- Valid AOC with operational specifications
- ARC for each aircraft (issued within 12 months)
- Certificate of insurance meeting EU 785/2004 thresholds
- Maintenance records and approved maintenance programme
- Crew licensing and qualification records
- MEL and technical log
- Noise certificate
- Leasing agreement
From the Lessee (Operator)
- AOC covering the aircraft type
- Operational approval documents (ETOPS, CAT II/III, RVSM)
- Route and network schedule
- Ground handling arrangements
- Fuel and landing permits
Temporal Compliance: Common Failure Points
Expired AOC: The most common reason for grounded wet leases. Set up monitoring at 90, 60, and 30 days before expiry.
ARC Lapse: ARC validity is 12 months. If the renewal window is missed, the aircraft cannot operate commercially until a new ARC is issued.
Insurance Gaps: Many operators carry blanket policies that don't specifically cover ACMI operations. The policy must name the lessee as an additional insured.
How AeroVectra Simplifies ACMI Compliance
AeroVectra's AI-powered platform automates the entire compliance verification pipeline:
1. Upload PDFs — AOC, ARC, and insurance certificates
2. AI Extraction — Two-stage Gemini AI classifies and extracts 28+ data fields
3. Cross-Validation — Insurance levels checked against MTOW bands per EU 785/2004
4. Expiry Tracking — Temporal alerts for all documents and approvals
5. Compliance Report — Machine-readable report ready for the lessee