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Compliance·1 July 20268 min read

The Complete EASA Compliance Checklist for ACMI Operators in 2026

A comprehensive checklist covering every EASA regulatory requirement for ACMI wet-lease operators — from AOC validity to EU 785/2004 insurance SDR thresholds.

The Complete EASA Compliance Checklist for ACMI Operators in 2026

Running an ACMI (Aircraft, Crew, Maintenance, Insurance) operation means every wet lease starts with a compliance clearance gate. One expired document can ground an aircraft for weeks and trigger regulatory penalties.

This checklist covers every EASA requirement you need to verify before signing a wet-lease agreement.

1. Air Operator Certificate (AOC) Validity

The AOC is the foundational document. Without a valid AOC, no commercial air transport operation is lawful.

- AOC issue date and expiry date

- Scope of operations (scheduled / non-scheduled / cargo)

- Approved aircraft types listed on the AOC

- Operational specifications (ETOPS, CAT II/III, RVSM, MNPS)

- State of the operator (must match the leasing jurisdiction)

Pro tip: EASA requires that the AOC remains valid for the entire duration of the wet lease. Set calendar alerts for renewal at least 90 days before expiry.

2. Airworthiness Review Certificate (ARC)

The ARC confirms the aircraft is airworthy. It must be issued or renewed within the last 12 months.

- ARC issue and expiry dates

- Aircraft registration (tail number) match

- ARC category (standard / restricted / provisional)

- Approved maintenance programme reference

- Any deferred maintenance items or airworthiness limitations

3. Insurance Certificates & EU 785/2004 SDR Compliance

EU Regulation 785/2004 sets minimum insurance requirements based on aircraft MTOW. Every ACMI operator must demonstrate coverage at or above these thresholds.

MTOW BandThird-Party Liability (min SDR)
< 500 kg750,000 SDR
500–2,700 kg1.5M SDR
2,700–6,000 kg3M SDR
6,000–20,000 kg8M SDR
20,000–50,000 kg18M SDR
50,000–200,000 kg98M SDR
> 200,000 kg180M SDR

- Verify third-party liability coverage meets MTOW band minimum

- Passenger liability minimum: 250,000 SDR per passenger

- Baggage liability minimum: 1,131 SDR per passenger

- Cargo liability minimum: 19 SDR per kg

- Insurance provider must be EASA-recognised

- Coverage must extend to the leasing period plus 30 days

4. Operational Approvals

EASA operational approvals are issued per aircraft type and require periodic renewal.

- ETOPS approval (current within 12 months)

- CAT II / CAT III low-visibility operations

- RVSM approval

- MNPS (North Atlantic) approval

- EDTO (Extended Diversion Time Operations)

- PBN / RNP AR approvals

5. Aircraft Fleet Documentation

- Registration certificate

- Noise certificate

- Certificate of insurance

- Leasing agreement (dry/wet lease)

- Maintenance programme status

- Component life limits tracking

- Technical log / journey log

- Minimum equipment list (MEL)

Automating the Checklist with AeroVectra

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