Introduction
On 2 February 2026, the European Union Aviation Safety Agency (EASA) published one of its most consequential evaluations in recent years. Prepared by Ecorys and the Royal Netherlands Aerospace Centre (NLR) under Framework Contract EASA.2021.FC17, the 156-page evaluation report scrutinises the proportionality and administrative burden of the regulatory framework governing commercial operators of small aeroplanes under Part-CAT and Part-SPO of Regulation (EU) No 965/2012, commonly known as the Air Operations Regulation.
The report arrives at a time when Europe’s aviation sector is under mounting pressure. Small commercial operators, many of them family-run or employing fewer than a dozen people, have long argued that they are subject to the same regulatory intensity as major airlines. This evaluation, triggered by a stakeholder request through EASA’s candidate issue register, finally puts hard numbers behind what the industry has been saying for years: the regulatory burden on small aeroplane operators is disproportionate, financially crippling, and in urgent need of reform.
Scope and Methodology
The evaluation targets commercial operators whose principal place of business is in an EASA Member State and who operate only small aeroplanes, defined as those with a maximum take-off mass (MTOM) below 5,700 kg. The scope includes operators who hold an Air Operator Certificate (AOC) for commercial air transport under Part-CAT, those conducting specialised operations (Part-SPO) including high-risk SPO authorisations, and operators who additionally fly helicopters alongside their small aeroplane fleets. Non-commercial operators and those operating only helicopters were excluded.
The research methodology combined four complementary data-collection instruments: desk research, a general survey that yielded 406 responses (with 67 operators ultimately included in the core analysis), a mini survey targeting national competent authorities (NCAs), and a structured interview programme involving operators, NCAs and aviation associations. The standard cost model was employed to estimate both business-as-usual costs and the administrative burden attributable solely to EU-level legal requirements. The survey coverage represents a significant sample of the estimated 502 operators falling within the evaluation’s scope across 31 EASA Member States.
Data collection was structured around five pre-identified areas of administrative obligation: application for an AOC, SPA, authorisation or declaration; compliance monitoring including changes to regulations; safety-management-related tasks; registration and monitoring of hours, training and related activities; and audits and inspections by national competent authorities.
Profile of the Typical Small Operator
The report paints a detailed picture of the average European commercial small aeroplane operator. These are overwhelmingly small and medium-sized enterprises (SMEs) managing modest fleets of approximately four aeroplanes and employing around 12 staff members. Of those staff, an average of 2.6 are dedicated to administrative activities. The range of commercial operations is diverse, spanning sightseeing flights, air taxi services, aerial survey work, parachuting operations and agricultural applications.
Annual turnover varies considerably, ranging from approximately EUR 200,000 to EUR 1.5 million. These are not large enterprises with dedicated legal, compliance and quality departments. In many cases, a single individual may simultaneously serve as the accountable manager, compliance monitoring manager and safety manager, a reality that the current regulatory framework appears to overlook.
The Scale of the Administrative Burden
The evaluation’s central findings are striking. The average commercial operator of small aeroplanes spends approximately 5,471 hours per year on compliance activities. This is equivalent to 2.8 full-time equivalents (FTEs). Of this total, 2,916 hours, or 53 percent, are classified as administrative burden, meaning they represent obligations that operators would not voluntarily undertake absent the regulatory requirement. This administrative burden alone consumes 1.5 FTEs per operator.
Extrapolated across the estimated 502 operators sector-wide, the total administrative burden amounts to approximately 1.46 million hours annually. When monetised using Eurostat standard tariff rates of EUR 37.16 per hour, the average operator faces an administrative effort cost of EUR 203,300 per year, of which EUR 108,400 constitutes pure administrative burden. Sector-wide, this translates to EUR 102.1 million in total administrative costs, with EUR 54.4 million attributable to administrative burden alone.
Burden Distribution Across the Five Areas
The report reveals significant variation across the five pre-identified areas. Compliance monitoring (Area 2) emerges as the single most burdensome domain, consuming an average of 1,826 hours per operator per year, at a monetised cost of EUR 67,589. Registration and monitoring of hours, training and related activities (Area 4) follows closely at 1,782 hours and EUR 66,211 annually. Safety-management-related tasks (Area 3) account for 1,274 hours and EUR 47,343. Audits and inspections by national competent authorities (Area 5) consume 495 hours, while application processes (Area 1) represent the smallest share at 95 hours.
Crucially, when the administrative burden (as opposed to total administrative effort) is isolated, Area 2 remains the largest contributor, with 45 percent of compliance monitoring time classified as burden, equating to EUR 37,627 per operator per year.
Administrative Effort and Burden at a Glance
Area | Hours/Year | Cost (EUR) | BaU % | Burden (EUR) |
| 1. Applications | 95 | 3,524 | 34% | 2,329 |
| 2. Compliance Monitoring | 1,826 | 67,589 | 45% | 37,627 |
| 3. Safety Management | 1,274 | 47,343 | 46% | 25,802 |
| 4. Records & Training | 1,782 | 66,211 | 51% | 32,746 |
| 5. Audits & Inspections | 495 | 18,396 | 46% | 9,865 |
| Total | 5,471 | 203,300 | 53% | 108,400 |
What makes these figures particularly alarming is their proportion relative to operator turnover. Anecdotal data gathered during the evaluation indicates that administrative obligations may consume approximately 15 percent of an average annual turnover of EUR 800,000. For one parachuting operator with an annual turnover of approximately EUR 800,000, reported net annual profit ranged from just EUR 5,000 to EUR 10,000, with administrative costs potentially exceeding 50 percent of that profit.
Beyond the Numbers: Qualitative Findings
Economic Impacts
The survey responses reveal a strong consensus that regulatory compliance imposes significant negative economic effects. Among respondents, 47 percent reported a large negative impact on profit margins, while a further 34 percent indicated a small negative effect. Regarding competitive capacity, 56 percent of operators reported a large negative impact, indicating that they cannot produce services at competitive prices due to the compliance overhead.
Operators consistently reported that one-off compliance costs, such as developing a Safety Management System (SMS) or drafting an operations manual, routinely evolve into recurrent financial commitments due to frequent regulatory changes, mandatory manual updates and ongoing training requirements. One operator reported that developing an operations manual cost EUR 5,000, a risk assessment EUR 2,000, and external audits between EUR 500 and EUR 1,500 each. Another estimated external audit services alone at EUR 35,000 to EUR 40,000 annually.
Social and Workforce Impacts
The social dimension of the burden is equally concerning. Operators reported reduced job attractiveness, increased staff fatigue, and significant difficulties in recruitment and retention, particularly for specialised roles. The administrative workload diverts personnel from core operational and safety activities, with operators estimating that without the current volume of administrative work, approximately 30 to 35 percent more hours could be flown and 20 to 30 percent of staff working time could be redirected to commercial activities.
For small organisations where individuals frequently fulfil multiple roles, the cumulative effect is especially acute. The report notes that in many cases, the administrative workload has had a chilling effect on innovation and growth, deterring operators from expanding their commercial activities or exploring new business models.
Safety Paradox
Perhaps the most nuanced finding concerns safety. Both operators and national competent authorities acknowledged improvements in safety culture, reduced incident rates and enhanced operational legitimacy attributable to the regulatory framework. However, a clear paradox emerges: the administrative burden itself may be undermining safety outcomes by diverting limited resources away from proactive risk management and direct operational oversight. When compliance becomes a paperwork exercise rather than a genuine safety tool, its value is fundamentally diminished.
Root Causes of Disproportionate Burden
The evaluation identifies several structural factors that drive the disproportionate burden on small operators.
A ‘one-size-fits-all’ framework: The current regulatory structure was designed with large commercial operators in mind. Operators consistently reported that the requirements are not sufficiently tailored to the realities of small-scale operations, resulting in excessive documentation, frequent updates and duplicated processes.
107 information obligations: The evaluation identified 107 distinct information obligations imposed on operators within its scope, many of which require similar information in multiple formats or for different regulatory purposes.
Inconsistent interpretation by national competent authorities: Cross-border operators face particular difficulty, as interpretations of the same rules vary significantly between EASA Member States, creating additional complexity and uncertainty.
Frequent regulatory changes: Ongoing amendments to rules and provisions convert initial one-off compliance investments into recurring financial commitments, placing continuous strain on limited organisational resources.
Lack of clear guidance: Ambiguous provisions and insufficient support from NCAs increase the risk of inadvertent non-compliance and drive reliance on costly external consultants.
The Ten Recommendations for Reform
Drawing on extensive stakeholder consultation and administrative burden analysis, the evaluation formulates ten targeted recommendations. Each is linked to a specific task in the European Plan for Aviation Safety (EPAS) 2025 edition, ensuring a direct pathway to implementation.
Recommendation 1 — Support applications for operational approvals: Re-engineer EASA guidance on AOC, SPA, authorisation and declaration applications to help NCAs better support operators through the process.
Recommendation 2 — Clearly define high-risk SPO: Facilitate the adoption of unified standards for how ‘high-risk’ specialised operations are defined and managed across Member States.
Recommendation 3 — Improve the proportionality of Operations Manuals: Review AMC and GM governing OM content and structure to ensure proportionality, recognising that small aeroplane operations cannot be modelled on airline CAT operations.
Recommendation 4 — Communicate changes to regulations: NCAs should improve how they communicate upcoming regulatory changes and provide practical support, examples and best practices to operators.
Recommendation 5 — Assess the proportionality of Safety Management Systems: Review SMS AMC and GM to ensure proportionality by reconsidering the definition of complex and non-complex operators in the context of safety management.
Recommendation 6 — Simplify the risk register: Reduce the example risk register in GM3 ORO.GEN.200(a)(3) to four essential fields: hazard and consequences, estimated risk level, mitigating measures, and verification of implementation.
Recommendation 7 — Simplify resolving non-compliance: Remove unnecessary fields from the non-compliance report form for non-complex operators, including category, root cause and suggested correction fields.
Recommendation 8 — Reassess requirements surrounding PEDs: Exempt commercial operators of small aeroplanes from conducting formal risk assessments for common portable electronic devices such as smartphones, tablets and laptops.
Recommendation 9 — Reduce the duplication of records: Facilitate sharing of best practices and practical templates for efficient record-keeping, minimising duplication across different regulatory requirements.
Recommendation 10 — Resolve different interpretations of the rules: Harmonise oversight and interpretation of regulations among NCAs through EASA-facilitated dialogue, ensuring consistent implementation across Member States.
Impact Assessment: What the Recommendations Could Deliver
Each recommendation was individually assessed against the baseline administrative cost, with results presented for both a base case and a sensitivity scenario. The sensitivity scenario applies a more conservative burden estimate of 34 percent (drawn from a previous EASA study on small helicopter operators) rather than the 53 percent indicated by stakeholder responses, thereby accounting for potential overestimation driven by frustration or subjective bias.
In the base case, individual recommendations deliver estimated reductions of between 6 and 10 percent against the baseline administrative cost in their respective areas. Under the more conservative sensitivity scenario, the reductions range from approximately 3 to 6 percent. For example, Recommendation 1 (supporting applications) is projected to reduce Area 1 costs by 9.9 percent in the base case and 5.1 percent in the sensitivity scenario. Recommendation 5 (SMS proportionality) could reduce Area 3 costs by 9.3 percent in the base case.
If all recommendations were implemented simultaneously, the combined impact could approach the European Commission’s target of a 25 to 35 percent reduction in administrative burden, though the report cautions that such combined effects should not be interpreted as strictly additive due to potential interactions between recommendations.
Social and Safety Dividends
The potential social benefits are significant. If fully implemented, the recommendations could deliver efficiency gains equivalent to 1.6 FTEs per operator, or 787 FTEs sector-wide. These represent upper-bound estimates, and practical constraints mean actual impacts would likely fall between the current baseline and these maximum values.
Safety impacts are expected to be positive. Stakeholders consistently reported that reducing unnecessary administrative workload would free time and attention for core safety management and operational oversight, foster a more proactive safety culture, reduce the risk of minor non-compliance, and support more effective risk management.
Critical Analysis and Implications
The evaluation represents an important milestone for the European aviation regulatory landscape. Several observations merit particular attention.
First, the distinction between burden arising from the type of aircraft operated and burden arising from the size and simplicity of the organisation is a crucial insight. The report acknowledges that much of the administrative burden stems not from the fact that these operators fly small aeroplanes, but from the fact that they are small organisations running simple operations. This suggests that future reform should consider organisational capacity as a primary factor in determining regulatory requirements.
Second, the most substantial reform recommended is the modification of SMS and Operations Manual requirements to make them more proportionate to operational realities. This is significant because these two domains, compliance monitoring and safety management, together account for the largest share of administrative burden and represent the areas where a ‘one-size-fits-all’ approach is most inappropriate.
Third, the report’s recommended next steps, including prioritisation of recommendations, establishment of a monitoring and evaluation framework, periodic reviews and continued stakeholder engagement, demonstrate a mature approach to regulatory reform. The emphasis on evidence-based decision-making and the recognition that implementation should be sequenced and monitored for unintended consequences are encouraging signs.
However, the report also carries implicit warnings. There is a risk that time saved on compliance could be redirected entirely to commercial activities rather than safety improvements. EASA must ensure that burden reduction is coupled with mechanisms that encourage operators to reinvest freed capacity into genuine safety enhancement.
Conclusion
The EASA evaluation of rules for commercial small aeroplane operators under Part-CAT and Part-SPO is a landmark document that provides, for the first time, comprehensive quantitative evidence of the regulatory burden facing Europe’s small commercial aviation sector. With an average operator dedicating 2.8 FTEs to compliance activities, spending EUR 203,300 annually on administrative effort and seeing up to 15 percent of turnover consumed by regulatory obligations, the case for reform is compelling.
The ten recommendations offer a practical, evidence-based roadmap for reducing burden while maintaining safety standards. The challenge now lies in implementation. EASA must prioritise the recommendations with the greatest potential impact, particularly those targeting SMS proportionality, compliance monitoring simplification and the harmonisation of NCA interpretations. The sector cannot afford another decade of incremental discussion while small operators continue to be squeezed between rising compliance costs and limited revenue.
For the 502 commercial operators of small aeroplanes across EASA Member States, this evaluation is not merely an academic exercise. It is a lifeline. The question is whether EASA and its Member States will act with the urgency that the data so clearly demands.
