Italian Charter Permits: What you need to know
Italian charter permits and associated requirements have changed a few times in recent years. Today, permit requirements vary depending upon where your aircraft is registered, passenger seating capacity, where you’re operating, and how recently you’ve conducted a charter operation to Italy. As a general rule, the Ente Nazionale per l’Aviazone Civile (ENAC), which is the Italian Civil Aviation Authority, is very strict in regard to regulations and to the documentation that needs to be submitted.
1. Italian charter landing permit requirements
All charter (non-scheduled commercial) flights by non-European Union (EU)-registered aircraft require landing permits. For any aircraft with up to 19 passenger seats, these operations are referred to as “air taxi flights,” and only annual charter permits are available. An annual charter permit covers an operator’s entire fleet, assuming all aircraft have been specified on the permit. The permit is only granted validity through the term of the insurance’s validity. For example, if the insurance is only valid for an additional six months at the date of application, then the permit will only be valid for six months.
- Air taxi
- An air taxi flight involves transport of passengers, with their own freight (baggage), under a single charter contract for the entire capacity of an aircraft having no more than 19 passenger seats.
2. Exemptions for EU-registered aircraft
EU-registered charter aircraft with 19 passenger seats or less do not require landing permits. While such operators should submit a ground handling request and file a flight plan, no special permit or notification is required by ENAC.
3. Processing of landing permits
Processing time for an annual Italian charter landing permit is 20 business days, assuming the operator has landed within the EU, as a charter, within the last two International Air Transport Association (IATA) seasons. IATA seasons are March-October and October-March. Otherwise, the permit processing time is 45 business days.
4. Permit processing hours
ENAC processes charter permits Monday-Friday, 0900-1700 local. The office is closed on weekends and holidays. No after-hours permit processing is possible under any circumstances, and after-hours contact numbers are not available.
5. Requirements for non-EU-registered aircraft
Operators applying for the first time charter to Italy – or those who have not operated to Italy during the past two IATA seasons – must submit specific documentation to the Italian Air Transport Development Division.
- Air Operator Certificate complete with operational specifications.
- Foreign Operator Questionnaire, validated by the aeronautical authorities of the applicant, is always required for air carriers performing flights with aircraft that have more than 19 passenger seats.
- Certificate of Registration and Airworthiness, along with a noise certificate and ACASII EGPWS equipment certification.
- Valid liability insurance issued according to EU Regulation 785/2004 and in compliance with ENAC’s standard form insurance requirements. Any authorized aircraft must be listed
- Letter of approval from the civil authority in which the aircraft is registered, certifying that the company’s security program complies with International Civil Aviation Organization Annex 17, and it must be signed by the Transportation Security Administration inspector who supervised the issuing document.
- Power of attorney (POA) authorizing the ground handler to obtain the permit on the operator’s behalf. This POA must be on the company’s letterhead and notarized (include a stamp and signature).
6. Domestic operations
Your charter landing permit specifies which Airports of Entry (AOEs) you may travel to within Italy. In order to travel to a domestic airport, you must first arrive/depart via an Italian AOE. Note that, for domestic travel within Italy, you may not carry passengers that are not associated with your international legs, which would be considered cabotage. In other words, you may not board any additional passengers that you did not bring into Italy. At some point in the future, it’s anticipated that Italy may expand its cabotage restrictions – to include travel to and within other EU countries – but this has not yet occurred, and no date for implementation has been announced.
7. TCO requirements
Ente Nazionale per l’Aviazone Civile (ENAC), the Italian Civil Aviation Authority, began requiring the Third Country Operator (TCO) authorization as part of the landing permit requirements in 2013. Specifically, until November 25, 2014, it was recommended that operators submit TCO authorizations, but this was not a requirement. As of November 26, 2014, TCO authorizations must be submitted with all Italian landing permit requests. If the TCO authorization is not submitted, your landing permit will not be processed.
8. Required information
When you request a charter landing permit, the following information/documentation is required:
- Air Operator’s Certificate (AOC)
- Operation specification D085 (aircraft listing)
- A003 aircraft authorization
- A999 certification statements
- Operator’s full address and information
- Insurance certificate for Italy (ENAC’s format) that must include all aircraft – both owned and leased fleet – that is being submitted for the permit—. ENAC’s specific verbiage and format need to be followed. You cannot use a generic EU insurance format, as that will be rejected.
- Letter from civil authority from the country in which the aircraft is registered, stating that the security program that the operator has complied with International Civil Aviation Organization Annex 17. This is usually found within the operator’s security program.
- A foreign operator’s questionnaire (FOQ) is only needed if the landing permit application is for aircraft with more than 19 seats.
- Letter to authorize your trip support provider to be able to process the permit on your behalf, as the 3rd-party provider will be representing the operator with submitting the application to ENAC. This letter needs to be on company letterhead, signed, and notarized. (This is a power of attorney.)
- TCO certificate – or proof that the application has been made (ENAC will double-check with the European Aviation Safety Agency that this has been done). The deadline for operators to submit for a TCO was November 25, 2014. This is the latest requirement that ENAC requires.
Additional notes: For the insurance, it needs to be in the special format provided by ENAC, and it’s recommended that the insurance that is submitted be valid for the year that the permit is valid. If this is an issue, another option is to submit the new insurance before the one submitted will expire. If this isn’t done, ENAC will not consider the permit valid, and if the operator travels to Italy after the original insurance was submitted, ENAC may fine the operator. ENAC holds the operator accountable for submitting updated documentation to ENAC, such as insurance.
9. Air Carriers – charter aircraft with more than 19 passenger seats
If your charter aircraft is not EU-registered and has more than 19 passenger seats, you’re considered an “air carrier” and must submit a different type of landing permit request, specifically for air carriers. This particular type of Italian landing permit is available as a one-shot or annual permit, which requires submission to ENAC with all relevant documentation, as well as a FOQ. Carriers applying to operate a first-time charter to Italy (or who have not operated a charter to Italy during the past two International Air Transport Association seasons) must submit their application to the Air Transport Development Division and include:
- A FOQ validated by the aeronautical authorities of the applicant – except for carriers registered in the U.S., Canada, and Turkey
- AOC with complete operational specifications
- Certificates of registration, airworthiness, and noise, as well as ACAS II EGPWS certification
- Insurance certificate issued according to EU Regulation 785/2004 and in compliance with ENAC standards (special format issued by ENAC)
- A completed security program
10. Processing time for an Italian air carrier landing permit
Processing time to approve an air carrier landing permit is 45 business days. When making a permit application, the operator may include all aircraft in the fleet with more than 19 passenger seats. Any aircraft with 19 or fewer passenger seats must be processed separately, under the “air taxi” classification. Note that EU-registered charter aircraft under the air carrier classification do not require permits but must submit a notification to ENAC with a minimum 24-hour lead time, and this notification must include an applicable flight schedule.
11. Permit revisions – for all charter permits types
Once a charter permit is approved, it can be revised if another aircraft needs to be added to the listed fleet. To do this, documentation for the additional aircraft is forwarded to ENAC, and the processing time is generally five business days. In order to completely renew an approved Italian landing permit, however, the lead time is 30 business days.
12. All-inclusive tour and special event charters
All applicants for inclusive tours and special event charter flights must also submit:
- A copy of the charter contract signed by the “airline” and the “tour operator.”
- Website address of the tour operator who advertised and sold the applicable flights in question.
- A shipper’s declaration listing the origin and/or destination of all goods on board the aircraft.
Application for traffic rights (landing permits) concerning all-inclusive tours and ad-hoc flights must be submitted five days in advance of a single flight and 15 days in advance in cases of a series of flights. Note that a special event charter flight is considered one where the aircraft is chartered for passengers attending a sport, cultural, professional, etc. events. For such flights, the origin and return destination (after traveling to Italy) must be the same, and it must be operated with aircraft that have more than 19 passenger seats.
13. Expedited permits
Expedited landing permits are normally only possible for diplomatic and/or air ambulance/emergency flights. In most cases, diplomatic flights – even though they may be charters – are exempted from Italian charter landing permit requirements, so long as they’re classified correctly and go through appropriate diplomatic channels for flight approval. It’s recommended that your 3rd-party provider confirm this information for your flight.
Keep in mind that if regulations are not followed, or proper documentation is not submitted, ENAC will not process your charter landing permit. For permit renewals, you’ll only need to submit documents that may have expired, or will expire shortly (within the next year). Documentation that remains valid does not have to be re-submitted with your annual charter permit renewal.
Lead times for Italian charter permits are firm, and short-notice permit requests are not normally possible. Note that once a charter permit application has been made, with all required documentation submitted, the operator may travel to Italy without notice once the permit is approved.
All TCO authorizations must be submitted with all Italian landing permit requests. Otherwise, your landing permit will not be processed. Note that landing permit requirements change for aircraft over 19 seats, and for inclusive tours and special event charter flights.
Always pay close attention to Italian cabotage restrictions and regulations. If you have questions on Italian cabotage restrictions, then it’s recommended that you speak with your 3rd-party provider.