EASA is reevaluating what qualifies as a CMPA, a process that could have a significant impact on the industry. The current definition shapes compliance requirements, oversight, and the actions that operators are allowed or required to take. For our members, that framework feels out of step with how their aircraft actually perform.

Why It Matters

Currently, the CMPA label is based on technical specifications:

An aeroplane:

•     With a maximum certified take-off exceeding 5,700 kg, or
•     certified for a maximum passenger seating configuration of more than nineteen, or
•     certified for an operator with a minimum crew of at least two pilots, or
•     equipped with (a) turbojet engine(s) or more than one turboprop engine, is considered to be a CMPA.

These once-convenient stand-ins for complexity do not reflect the current operational realities, as the landscape has changed.

Many aircraft now exceed the CMPA thresholds without being truly “complex” in how they’re flown or maintained. At the same time, some aircraft that fall under the thresholds might present higher operational demands. The result is a definition that feels increasingly mismatched with reality and is often burdensome.

For our members, that misalignment is obvious. Operators of single-pilot jets, high-performance piston engines, or even next-generation electric aircraft are navigating a system that wasn’t built for them. The consequences range from excessive paperwork to limited operational flexibility, all without a clear safety benefit.

There’s also the international angle. Aircraft and operators coming from outside the EU often fall under different definitions, which creates uneven conditions and adds friction to cross-border operations.

What We’re Working On

EBAA is actively involved in the process and participates in EASA’s CMPA Expert Group, working closely with stakeholders and regulators throughout the assessment.

The EBAA position will be defined over the next few weeks in collaboration with industry experts and the EBAA Flight Operations Working Group. A key requirement is that the definition of complexity accurately reflects the realities of aircraft operation, not just what they appear to be on paper.

Our goal is to ensure that CMPA rules are consistent across all regulatory domains. It doesn’t make sense for the same aircraft to be classified differently in OPS, airworthiness, or crew regulations.

Newer technologies and propulsion systems should be evaluated based on their performance in real-world operations and adequately reflected in future regulations. 

What’s Next

This impact assessment isn’t the end of the process. EASA is expected to publish a draft regulation based on the survey results and the broader consultation. Once that’s available, there will be another opportunity to respond, and the EBAA will be ready to engage again based on the position developed by its working group.

We thank everyone who took the time to complete the survey. Your input adds weight to the case for smarter, more proportionate rules.

We’ll keep you updated on what comes next. If you’d like to share your experience or concerns about CMPA regulations, please contact Adem Agko. We’re listening.