The European Union Aviation Safety Agency (EASA), in partnership with Ecorys and the Royal Netherlands Aerospace Centre (NLR), is evaluating the proportionality of operational rules that apply to commercial aeroplane operators across Europe. The focus is on Part-CAT and Part-SPO of Regulation (EU) No 965/2012, which outlines the EU’s air operations requirements.

At the heart of this initiative is a simple but essential question: are current rules placing unnecessary or disproportionate burdens on operators, particularly those flying aircraft with a Maximum Take-Off Mass (MTOM) of 5,700 kg or less? EASA wants to hear directly from the people navigating these obligations every day. Based on the survey findings, the project team will develop recommendations to streamline the framework without compromising safety.

Although the survey is labelled for “small-size” aeroplane operators, the scope is intentionally broader. A wide range of stakeholders are encouraged to participate, including:

• Cost-sharing platforms operating without an AOC
• Business operators with aircraft above 5,700 kg contributing to research and comparison
• Aviation associations representing small and medium operators
• National competent authorities

This inclusivity ensures that a fuller range of operational realities is captured, including those of many EBAA members, regardless of fleet size. If Part-CAT or Part-SPO governs your organisation, this is your opportunity to help shape future rules.

Proportional regulation—and ideally, AOC regulations similar to the U.S. Part 135 framework—has been EBAA’s long-standing strategic objective for over a decade. This survey marks a crucial first step in making EASA aware of our sector’s unique requirements and operational realities and the effectiveness of a more tailored, lower regulatory approach.

This initiative allows EBAA members to directly communicate their concerns and operational challenges to EASA by engaging a broad cross-section of our membership. We strongly encourage you to participate in the survey and ensure your voice is heard in this vital regulatory review process.

Beyond identifying problems, the survey also aims to capture good practices, highlight areas where current requirements work, and flag those needing to evolve. The insights you provide will directly inform EASA’s analysis. A draft of the findings will be presented at a stakeholder workshop in December 2025, and there will be further opportunities to contribute before any changes are finalised.

The survey is open until 30 May 2025. It’s available online and will adapt based on your role. Select your stakeholder type at the start. Responses are anonymous, and thanks to a pause and save feature, you can complete the survey in stages. You may also be invited to take part in a confidential follow-up interview, should you wish to do so.

Click here to take the survey.

If you have questions about the survey itself, you can reach the evaluation team at:

EASA-study-small-operators@ecorys.com

For anything specific to your operations or to discuss the survey further, don’t hesitate to get in touch with me directly:

Adem Agko (EBAA) – aagko@ebaa.org

This is a unique chance for business aviation to help shape a more effective, balanced, and proportionate regulatory framework. Your input won’t just be appreciated—it will be impactful.