The proposed regulation sets out a tiered fee structure based on operator category (light or heavy) and fleet size. The charges include:

• Authorisation fee: €750–€3,000
• Monitoring fee: €1,500–€6,000
• One-off notification fee: €1,800

Although not a single flat rate, this banded approach remains blunt. It does not scale proportionally with activity or oversight, meaning smaller operators face a disproportionate financial burden compared to larger fleets.

Why this matters for business aviation

At first glance, the proposal may seem to concern only large international airlines. In reality, it carries serious consequences for business aviation.

• Direct impact on UK operators: Following Brexit, UK AOCs (many of which are EBAA members) qualify as Third Country Operators and are directly subject to the new fees.
• Indirect impact on EU operators: Other countries, notably the United States, currently waive TCO fees on a reciprocal basis. If EASA imposes these charges, equivalent or higher fees could be introduced abroad. For operators conducting frequent transatlantic flights, this would translate into a significant additional cost burden.
• SMEs disproportionately exposed: Most business aviation operators are small and medium-sized enterprises. Tiered fees, applied without consideration for the scale of oversight needed, create a barrier to entry and undermine the economic resilience of smaller operators.

The timing compounds the problem. Business aviation is already facing rising costs due to the expansion of the ETS, the RefuelEU, and the proposed Energy Taxation Directive. Layered together, these measures threaten the financial sustainability of our sector.

Key concerns

EBAA, alongside its partners, has identified three fundamental flaws in the proposal:

1.Cost escalation and international repercussions

EASA claims the financial impact will be minor. But the precedent it sets is dangerous. Other regulators are likely to introduce reciprocal charges, multiplying costs across global networks. Ultimately, EU operators would be among the most severely affected.

2.Lack of transparency

The cost basis for the proposed fees has not been explained. The disparity with other regulators is stark: the UK CAA charges just £96 (about €115) for a TCO approval. By contrast, EASA’s charges appear exorbitant and unjustified.

3.EASA’s expanding remit

EASA’s responsibilities are broadening into non-safety areas such as sustainability and multimodal transport. While these are important, they should be funded by EU institutions. Operators cannot be expected to cross-subsidise tasks unrelated to safety oversight.

EBAA’s advocacy

On August 20, EBAA submitted a detailed response to the EASA Stakeholder Advisory Body (SAB) consultation, clearly outlining our opposition to the proposals.

In parallel, EBAA joined forces with IATA, co-signing an industry-wide letter that was sent to all National Aviation Authorities (NAAs) and presented at the 42nd ICAO Assembly in Montreal. This joint action underscores the global nature of the issue and the risks associated with unilateral EU action.

EBAA is also coordinating with the National Business Aviation Association (NBAA) to ensure transatlantic advocacy is aligned, given the likelihood of U.S. countermeasures if the EU proceeds with TCO charges.

What’s next

The SAB input has now been delivered and will inform the discussions of the EASA Management Board. The European Commission is expected to table the proposal for a vote in the EASA Committee on 21–23 October.

Between now and then, EBAA will:

• Advocate for suspension of the proposed TCO fee structure.
• Demand transparency on EASA’s cost calculations.
• Defend the interests of SMEs and smaller operators.
• Continue working with IATA, NBAA and other stakeholders to deliver a unified industry message.

Our message

Business aviation is ready to contribute to the sustainable financing of aviation safety. But fees must be transparent, proportionate, and fair. EASA’s current proposal does not meet that standard. It risks penalising SMEs, undermining competitiveness, and provoking retaliatory measures from international partners.

EBAA will remain vigilant in protecting the interests of its members and will continue to engage constructively with regulators and policymakers to ensure that EASA’s financial sustainability does not come at the expense of the economic sustainability of European business aviation.

We will keep you, our members, informed of developments as progress continues. If you want to learn more about EASA’s TCO Fee Proposal or contribute to the conversation, please get in touch with Adem Agko.