Attention:
Prospective foreign operators seeking a Foreign Air Operator Certificate – Free Trade Agreement (FAOC-FTA) to conduct commercial operations in Canada using experimental or ex-military aircraft holding restricted-category certification.
| File Classification No.: | Z 5000-35 |
|---|---|
| RDIMS No.: | 21230449 |
| Document No.: | CASA 2025-12 |
| Issue No.: | 01 |
| Effective Date: | 2025-11-20 |
Purpose:
The purpose of this Civil Aviation Safety Alert (CASA) is to inform existing and prospective foreign operators that, effective on the date of this publication, Transport Canada Civil Aviation (TCCA) will cease to accept or consider applications for the issuance of a Foreign Air Operator Certificate – Free Trade Agreement (FAOC-FTA) where the intent is to operate under Specialty Air Services – Free Trade Agreement – Canada-United States-Mexico Agreement (CUSMA) using experimental or ex-military aircraft holding restricted-category certification.
This policy aligns with the intent and safety expectations previously established for domestic operators under CASA 2024-06, which reinforces the need for uniform safety standards across all operations in Canada. It also reaffirms Canada’s commitment—together with the United States of America and Mexico—that experimental or ex-military aircraft with type certificates derived from military experience are not authorized for specialty air services operations.
Background:
As outlined in CASA 2024-06, there has been a notable rise in commercial operations utilizing ex-military aircraft for aerial work purposes. This trend may signal a significant shift in the risk landscape. While CASA 2024-06 primarily addressed domestic operations, similar safety concerns persist in cases where operations are conducted under a FAOC-FTA.
This situation was influenced in part by a temporary deviation granted by the U.S. Federal Aviation Administration (FAA) in 2023, which permitted exceptions to the requirements outlined in Advisory Circular (AC) 00-6B. TCCA acknowledges that this deviation was implemented to address increased operational demands, particularly the need for additional aircraft capacity to support wildfire suppression and management efforts within Canada. With the understanding that this temporary measure is approaching its expiry, TCCA is taking immediate steps to reinforce its policy position and ensure continued alignment with long-term safety and regulatory objectives.
On October 2, 2025, TCCA released a Preliminary Issue and Consultation Assessment (PICA) to evaluate the potential use of foreign ex-military aircraft in Canadian commercial aviation, with a consultation period ending December 12, 2025. This assessment outlines the key factors TCCA is considering in evaluating the potential introduction of such aircraft into civil commercial operations.
The analysis focuses on safety, policy continuity, public benefit, and market demand. Canada’s civil aviation system is founded on rigorous certification standards designed to ensure that aircraft meet civilian safety requirements—standards with which many military-designed aircraft have not demonstrated compliance.
While earlier policies permitted limited transfers of ex-military aircraft into commercial service, newer and more complex models present greater challenges in demonstrating equivalent levels of safety, particularly when the applicants are not the original manufacturers. At the same time, growing demand for aerial firefighting and other specialized missions highlights the potential public benefits of expanding aircraft availability.
TCCA’s decision will ultimately seek to balance the potential public and operational benefits of integrating ex-military aircraft into commercial service against the associated safety risks, regulatory obligations, and broader economic considerations—including access to affordable aircraft for specialized missions.
Existing authorizations will remain valid until their respective expiry dates. FAOC-FTA applications already received by TCCA will be assessed in accordance with the current regulatory requirements.
Notwithstanding the above, TCCA will consider requests when there are exceptional situations, such as an emergency or immediate need for specific operational capacities.
Recommended action:
Operators intending to acquire or operate such aircraft for commercial use in Canada should carefully consider this policy change. TCCA will not be accepting new applications for the issuance of a FAOC-FTA where the intent is to operate Specialty Air Services under CUSMA using restricted-category experimental or ex-military aircraft.
Existing operators are encouraged to review their current authorizations and contact the TCCA Foreign Operations Division for clarification on how this policy may affect ongoing or future operations.
All interested parties are encouraged to provide feedback to the PICA.
Contact office:
For more information concerning this issue, or to comment, contact Standards Branch Documentation Services
E-mail: AARTDocServices-ServicesdocAART@tc.gc.ca
Original signed by
Jamie-Lee MacDermid
Executive Director
Standards Branch
The Transport Canada Civil Aviation Safety Alert (CASA) is used to convey important safety information and contains recommended action items. The CASA strives to assist the aviation industry's efforts to provide a service with the highest possible degree of safety. The information contained herein is often critical and must be conveyed to the appropriate office in a timely manner. The CASA may be changed or amended should new information become available.