Operator Certification Bulletin No. 01/26

Subject

Coming Into Force – Commercial Air Services Standards (CASS) Omnibus Amendments

Purpose

This bulletin is to inform Canadian air operators and Transport Canada Civil Aviation (TCCA) inspectors of the coming into force of the Commercial Air Services Standards (CASS) Omnibus amendments.

Background

The CASS Omnibus package (Notice of Standard Amendment (NSA) 2025-006) was published in October 2025, with a six-month implementation period. As such, the amended standards came into force on April 10, 2026.

While the amended standards are in force as of April 10, 2026, Transport Canada recognizes that implementation will require a transition period.

These amendments introduce a broad range of changes across multiple standards, many of which require updates to Company Operations Manuals (COMs), training programs, and associated operational processes.

Links to CASS by subpart

• CASS 722
• CASS 723 Aeroplane
• CASS 723 Helicopter
• CASS 724 Aeroplane
• CASS 724 Helicopter
• CASS 725

Note: Standards that have been amended via NSA 2025-006 (CASS Omnibus) will be indicated at the bottom of the associated standard as follows:
(effective 2026/04/10 – NSA 2025-006)
The associated hyperlink in the CASS will open the published NSA which provides hyperlinks to the original Notice of Proposed Amendment (NPA) where the rationale for the changes may be found. This is a new feature added to amended standards that will be used in future standards amendments.

Implementation Approach

TCCA recognizes that the scope and volume of these amendments represent a significant implementation effort for both air operators and inspectors.

As previously communicated to stakeholders, TCCA will adopt a phased, education and transition-focused oversight approach to support implementation of the amended standards.

National consistency in implementation and oversight remains a key objective during the transition period.

During this transition period:

• inspectors are expected to focus on awareness, education, guidance, and progressive implementation, rather than enforcement.
• air operators are expected to take reasonable steps toward compliance, including initiating updates to COMs, training programs, and associated operational processes.
• implementation progress should be proportionate to the complexity and operational impact of the applicable amendments and discussed with the operator’s Principal Operations Inspector (POI), as appropriate.

Oversight and Enforcement

In line with this approach, except where significant safety concerns or deliberate non-compliances are identified, findings related solely to the amended CASS provisions are generally not expected to be raised prior to October 10, 2027.

This period is intended to:

• provide sufficient time for operators to implement required changes;
• allow inspectors to support consistent national application; and
• enable TCCA to address any emerging issues or required clarifications.

Tools and Guidance

To support implementation and promote a consistent understanding of the new requirements, the Air Operator Certification Manual – TP 4711 and associated conformance reports have been updated to reflect the amended CASS provisions.

These Conformance Reports:

• identify the new and amended standard requirements;
• provide a structured means for both air operators and inspectors to assess implementation and compliance;
• serve as a primary tool to facilitate communication between the air operator and the POI regarding how requirements are being met; and
• support implementation planning by helping identify impacted procedures, manuals, training programs, and operational processes.

The Conformance Reports are effective immediately and should be used as the principal reference to:

• validate updates to Company Operations Manuals (COMs);
• support implementation planning and tracking; and
• identify areas where further alignment or improvement may be required.
• reference Air Operator Certification Bulletin 02/25 for additional information

Expectations

Air operators should:

• review the amended standards in detail;
• initiate updates to their COMs, training programs, and internal procedures;
• use Conformance Reports to support implementation planning and engagement with their POI; and
• maintain ongoing communication with their POI regarding implementation progress and challenges, where applicable.

Inspectors should:

• support operators through guidance and engagement;
• promote awareness of the changes by forwarding this bulletin to their respective air operators and recommend they subscribe to these bulletins. See active Air Operator Certification Bulletins with link to sign up;
• utilize updated conformance reports as a primary oversight tool; and
• apply a consistent, non-punitive approach during the transition period.

Guidance for inspectors reviewing COMs for approval during transition period

During the transition period that runs until October 10, 2027, if the air operator’s COM does not meet NSA-2025-006 CASS content at the approval phase, inspectors shall continue to process and approve COMs that meet pre-CASS Omnibus requirements for existing air operators, subject to the following conditions:

• 1) Each COM approval letter shall be accompanied by a note to the air operator advising that the approved COM does not yet reflect the amendments introduced by NSA-2025-006 and that a further amendment is required to meet the new CASS requirements. Additionally, inspectors shall indicate that the revised COM must be submitted and approved before the end of the transition period of October 10, 2027.
• 2) The approval letter shall indicate that the manual is being approved in accordance with the applicable CAR requirements and deviations permitted by Operator Certification Bulletin No. 01/2026.
• 3) The approval letter should reference TC's Stakeholder Engagement Strategy and the phased oversight timeline, so the operator understands both the obligation and the timeline.
• 4) Inspectors should maintain these notices/letters in an official repository and ensure follow-up amendments are received and approved before the enforcement phase begins.
• 5) Provide current conformance reports to the air operator and explain that new requirements are highlighted in green. Inspectors can find the most recent conformance reports in the TP 4711 tools list in RDIMS # 13610357.

Note: This process only applies to existing air operators. Existing and new applicants for an AOC must meet all CASS requirements prior to issuance of an initial AOC.

Guidance for inspectors reviewing COMs during surveillance activities during transition period

When conducting surveillance activities during the transition period on air operators whose COM is compliant with pre-CASS Omnibus standards but does not fully meet the CASS Omnibus requirements:

• 1) A question has been added to compliance inspections, asking if the CAD holder submitted an amendment to their COM and/or Training Program to address the changes to the CASS introduced under the Omnibus Regulatory Package.
• 2) The enterprise will be informed of not meeting the CASS omnibus requirements by way of the surveillance closing letter, advising that the approved COM does not yet reflect the amendments introduced by NSA-2025-006 and that a further amendment is required to meet the new CASS requirements by October 10, 2027.

Annex A – Key Changes

1. Documentation to be Carried on Board

Air operators are required to ensure that specific operational documents are carried on board aircraft, including a passenger manifest, cargo manifest, and a certified true copy of the Air Operator Certificate (AOC), aligning with ICAO standards.

2. Establishment of Check Authority Framework

New standards establish a formal framework for oversight of delegated personnel such as Approved Check Pilots and Dispatchers, incorporating applicable Transport Canada manuals and guidance for the conduct of checks.

3. Management of Deficiencies in Delegated Tasks

Requirements have been introduced to ensure that deficiencies identified in delegated checking activities are systematically addressed and resolved.

4. Standardized COM Structure

Company Operations Manuals must now follow a prescribed structure consisting of general information, aircraft operating information, areas/routes/aerodromes, and training requirements.

5. Procedures to Update COMs

Operators must include formal procedures to ensure that Company Operations Manuals are updated in accordance with regulatory changes.

6. Preservation of Flight Recorder Records

COMs must include procedures to preserve flight recorder data and associated equipment following an accident or incident.

7. ATC Clearance Procedures

Operators must include procedures addressing the clarification and acceptance of air traffic control clearances, particularly where terrain clearance is involved.

8. GPWS/TCAS Database Management

Operators must include procedures for managing and updating navigation and terrain databases to ensure data accuracy and operational safety.

9. Enhanced Company Route Information

Requirements for company route information have been expanded to ensure sufficient operational detail is available to support safe flight operations.

10. Modernized Training Program Requirements

Training program standards have been updated to reflect modern training practices, including improved training facilities and the inclusion of operational support services training.

11. Clarified Qualifications for Training Personnel

Enhanced requirements clarify the experience, knowledge, and competency expectations for instructors, training pilots, and examiners.

12. Weather and Volcanic Activity Reporting

COMs must include procedures for reporting routine and non-routine weather observations, including volcanic activity.

13. Operational Support Services and Equipment

Requirements have been expanded to ensure the use of current aeronautical information (AIRAC) and to include additional operational support elements.

14. Aerodrome Operating Minima (Aeroplanes)

Operators must describe in their COM the method used to determine aerodrome operating minima.

15. Heliport Operating Minima (Helicopters)

Helicopter operators must describe the method used to determine heliport operating minima.

16. Expanded Responsibilities of the Operations Manager

Responsibilities now explicitly include oversight of ground handling, operational support services, and subcontracted functions.

17. Ground Handling Training Requirements

Training programs must now include ground handling training, including for subcontracted personnel.

18. Accountability for Contracted Ground Handling

Operators must retain responsibility for ground handling activities even when these are subcontracted, and reflect this in their COMs.

19. Dangerous Goods Training Clarification

Training requirements for the transportation of dangerous goods have been clarified to align with applicable regulations.

20. Additional Equipment Requirement (Single-Engine Operations)

Single-engine passenger operations conducted at night or under IFR now require airborne weather radar.

21. Communicable Disease Procedures

Operators must include procedures to identify suspected communicable diseases and ensure timely reporting to ATC.

22. Flight Data Recorder Documentation (Maintenance Standards)

Maintenance standards now require documentation supporting the preservation and availability of flight data recorder information for investigations.

23. Miscellaneous Amendments

A number of minor editorial, grammatical, and administrative updates have been made across multiple standards.

Annex B – Affected CASS Sections

Commercial Air Service Standard 722 – Aerial Work

Commercial Air Service Standard 723 – Air Taxi Operations

Commercial Air Service Standard 724 – Commuter Operations

Commercial Air Service Standard 725 – Airline Operations

Annex C – CASS Omnibus FAQ

Note: We have received additional questions related to some of the provisions contained in the CASS omnibus, and a future air operator certification bulletin will be sent to address them in a similar manner below.

Ground Training Programs – TCCA Oversight

1. Does ground handling training constitute a training program requiring TCCA approval prior to delivery?

Yes, the TP 4711 requirement for approval of the training program, including operational support services, before delivery must be met.

The training program in ground handling must include all elements of ground handling applicable to the air operator. This includes:

• 1) ramp operations,
• 2) passenger services,
• 3) baggage services,
• 4) cabin services,
• 5) weight and balance control,
• 6) ground support equipment (maintenance and operation),
• 7) fuel services, and
• 8) any other ground handling arrangements and procedures for any service necessary for an aircraft’s arrival at, and departing from an airport, other than air traffic services.

For a complete description of ground handling services, refer to the ICAO Doc 10121 Manual on Ground Handling, Appendix B.

Until further guidance is developed, an inspector reviewing the program is expected to check that training for each element is present but will not be assessing its suitability. Note that some of the above have detailed requirements in the Canadian Aviation Regulations (CARs) and Commercial Air Service Standards (CASS). Assessment of these programs will not change.

Where expediency is required, TP 4711 allows for conditional approvals. Until further guidance with respect to minimum training standards is developed, conditional approval of the training program for ground handling should not be unreasonably denied.

2. How would the third-party training in a foreign country need to be handled?

Under the Aeronautics Act, Canadian Aviation Document holders must comply with or be operated in accordance with the applicable aeronautics laws of that State. In addition, every person committing an act or omission outside Canada, that if committed in Canada would be a contravention, shall be deemed in contravention of the provisions of the Act.

Any training of ground handling personnel in a foreign country must meet the requirements of that State and also be in accordance with the CARs and CASS.

For instances where training is conducted by a 3rd party, whether in Canada or abroad, refer to TP 4711, Volume 2 section 5.3.1 (a) to (e) which, although described as a requirement for crew training, would be an acceptable method of compliance for ground handling training. In this case, type training could be interpreted as aircraft-specific training. The guidance states:

• (1) An operator may contract crew member training to another organization provided:
  • a) the arrangement is clearly provided for in the approved training program;
  • b) the outside organization uses the manuals and publications used by the operator (COM, SOPs, AFM, AOM, etc., as applicable);
  • c) the operator ensures that the training is conducted in accordance with their approved program;
  • d) where type training is conducted, the training is provided on the type and model operated by the operator, unless otherwise provided for in their approved training program; and
  • e) the operator maintains training records as required by the Subpart they operate under.

3. Who within Transport Canada is trained and authorized to review and approve ground training curricula?

Until further guidance is developed, inspectors will be reviewing the ground operations training programs to ensure that the syllabus includes the new requirements but will not be approving the content. Additional training or authorization is not required currently. Note that some of the elements have detailed requirements in the CARs and training standards. Assessment of these programs will not change.

A certification team will consist of personnel assigned in accordance with TP4711 Volume 1 section 3.2.4 Assignment of the Certification Team. The Certification Project Manager will assign individual responsibilities as they deem appropriate.

4. Are ground handling training programs subject to TCCA Surveillance, and if so, under what regulatory authority?

Yes, ground handling training programs are subject to TCCA Surveillance.

For issuance and continued authority to operate, TCCA is required to ensure all CASS elements have been met prior to issuance of an AOC and to verify that these elements continue to be met through surveillance. This includes new ground handling training requirements, as well as existing certification requirements listed in subsection .07(2) of each relevant Subpart of CARs Part VII. For example, subsection 705.07(2) of the CARs states that: an applicant shall have …

• (g) a training program that meets the requirements of this Subpart;

and section 705.09 of the CARs states that: An air operator certificate shall contain the following general conditions...

• (d) the air operator shall conduct training in accordance with its training program approved pursuant to this Subpart;

An inspection under this authority would ensure the training program meets the requirements of the subpart and that training has been conducted in accordance with the training program identified in the COM. If the conditions of issuance are not met, the Minister may create a finding with possible enforcement, conduct enhanced monitoring, or decide to suspend or cancel the applicable AOC.

5. What regulations would be used to assess compliance and who would conduct such surveillance?

The air operator shall conduct training in accordance with its training program approved pursuant to the applicable subpart of the CARs. TCCA may conduct inspections to verify continuing compliance with certification requirements.

6. Will the current manuals dealing with such issues which are currently non TCCA approved documents, (i.e. Aircraft Servicing Manual, Fueling Manual, Cabin Grooming Manual, etc.) remain as non TCCA approved manuals?

Any manual containing procedures for operational support services applicable to the air operator, including ground handling, is considered part of the COM and will be approved in accordance with the following:

1. The Minister shall issue or amend an application for an air operator certificate where the applicant meets the requirements of the CARs and demonstrates to the Minister, the ability to, among other requirements: meet training program requirements, meet the Commercial Air Services Standards for the Operation and conduct the operation safely.
2. The applicant shall have a Company Operations Manual that meets the requirements of the applicable CARs and contains the information required by the Commercial Air Service Standards.
   1. The manual may be issued in separate parts corresponding to specific aspects of the operations and shall include the instructions and information necessary to enable the personnel concerned to perform their duties safely.
3. The Minister shall, where the Commercial Air Services Standards are met, approve those parts of a company operations manual that relate to the information required by the CARs of the applicable Subpart (e.g. Section 705.135 of the CARs – Contents of [the] Company Operations Manual).
   1. Where a ground handling service does not have requirements detailed in the CARs, CASS, conformance reports or associated guidance, approval will consist of a review to ensure that the required procedures are present.
4. In all cases, in accordance with TP 4711 Volume 1, Section 3.2.5.3.4.3 (7), the manuals shall include the instructions and information necessary to enable company personnel to perform their duties safely, and in compliance with the CARs, CASS, AFM, etc.

Ground Handling Procedures, Subcontracting Policies, and Approval Expectations

1. Does inclusion in the COM automatically imply approval of the underlying procedures?

The contents of the COM are approved in accordance with CARs/CASS, TP4711 and the associated conformance reports. Where detailed requirements exist, ground handling procedures in the COM will be assessed and approved accordingly. However, where specific requirements and guidance do not yet exist, the procedures must be present, but the suitability of the procedures will not be assessed during the review of the COM in the certification phase.

However, the procedures are subject to inspection for suitability. This is not a change from current practice. Refer to TP 4711, Volume 2, Chapter 6, Inspections, paragraph 6.1 which states:

The purpose of this phase of the certification process is to ascertain, through on-site inspections, the adequacy and suitability of the applicant/operator's organizational structure, operational control system, record keeping, facilities, aerodromes, ground equipment, and associated procedures used to conduct the operations specified in the application.

Operational Support Equipment and Services are subject to inspection, to the extent possible, with primary emphasis on the adequacy, suitability, and the safety aspects of its use. See TP 4711 Volume 2, Chapter 6, Paragraph 6.5.2 Operational Support Equipment and Services for more information.

2. Are ground handling procedures and subcontracting policies contained in the COM subject to TCCA approval?

Yes, ground handling procedures and subcontracting policies contained in the COM are subject to TCCA approval in accordance with TP4711. See the responses to 1 above with respect to approval of ground handling procedures.

See TP4711 Volume 2 Section 4.2.31 Operational Support Services & Equipment for details with respect to required information to be included in formal arrangements with third party service providers.

Company Operations Manual - TP4711 Section 4.2.3 COM Structure and Table of Contents

1. For a Company Operations Manual (COM) organized by phase of flight, is it acceptable to identify the applicable mandatory COM sections at the section level rather than annotating each individual page?

The Conformance Report, for example CR COM 705, includes instructions with respect to identification of the relevant section of the COM. In all cases, the location of each reference should be as specific as possible and should contain the name of the manual, chapter, section and paragraph numbers.

The section to which content applies should be clear to the reviewer. See TP 4711 Volume 2 4.2.3.11(b)(ii) for guidance on acceptable means of compliance for currently approved COMs.

2. Does identifying the mandatory four sections of the COM within each section’s Table of Contents constitute a “similar means” as contemplated under TP 4711 Volume 2 4.2.3 11(b)(ii)?

If an inspector can identify the section to which the content belongs, it meets the requirement.

Effective Date

Immediately.

Contact Office

Flight Technical and Operator Certification
Commercial Flight Standards (AARTF)
tp4711@tc.gc.ca

Approved by

Yvan Chabot
Special Advisor to the Executive Director, Standards