Transport Canada held an online consultation from February 10 to April 30, 2026, to gather feedback on proposed amendments to Schedule VI of section 104 of the Canadian Aviation Regulations. The proposed changes would modernize fees and service standards for aircraft airworthiness and maintenance approval services.
As part of this proposal, we also sought feedback on the proposed increase to the hourly rate for aeronautical product approvals under Schedule V of the Canadian Aviation Regulations (CAR 104.03) to better reflect the cost of delivering specialized services.
This report summarizes what we heard during the consultation.
On this page
Consultation approach
From February 10 to April 30, 2026, we held an online consultation for 79 days to gather feedback from aviation stakeholders, Indigenous groups and the public on the proposed changes to:
- fees and service standards for aircraft airworthiness and maintenance approval services under Schedule VI of the Canadian Aviation Regulations
- the hourly rate for aeronautical product approvals under Schedule V of the Canadian Aviation Regulations
To invite stakeholders’ feedback, we:
- published the consultation on Transport Canada’s Let’s Talk Transportation
- emailed members of the Canadian Aviation Regulation Advisory Council (CARAC)
- met with aviation associations to discuss the proposal
- shared information in Transport Canada’s National Indigenous Engagement Opportunities Bulletin
- encouraged associations to share the consultation with their members and provided material to support outreach
We received:
- 30 written responses to questions on the Let's Talk Transportation website
- 4 written submissions by email
- verbal feedback during 3 virtual meetings with associations
We heard from:
- general public
- industry representatives
- associations
What we heard
Theme 1: Perspectives on proposed fee changes
Feedback on Schedule VI
Participants shared their views on the proposed fee changes and how they may affect the cost of aircraft ownership, maintenance, and approvals.
Participants said that the proposed increases are significant, particularly for certificates of airworthiness, maintenance approvals, and other regulatory services.
Participants told us that:
- aircraft ownership and maintenance involve high and ongoing costs, including fuel, parts, and inspections
- the proposed fees may have a greater impact on individual aircraft owners, small operators, and non-commercial users
- some fees apply to mandatory regulatory requirements, which limits their ability to manage costs
- the timing of the proposed increases may create additional financial pressure for some parts of the aviation sector
- aircraft airworthiness services provide a broader public benefit, including safety for passengers and people on the ground
Participants suggested:
- phased implementation to allow time for adjustment
- assessing cumulative impacts across all fee categories
Overall, participants emphasized the importance of keeping costs predictable and proportionate, especially for smaller operators in the aviation sector.
Feedback on Schedule V
Participants commented on the proposed increase to the Schedule V hourly rate for aeronautical product approvals.
Participants noted that:
- the hourly rate was previously increased in June 2023 and some questioned whether another increase is needed at this time
- there were concerns about invoice billing related to the previous fee increase
Theme 2: Service standards and service delivery
Feedback on Schedule V and VI
Participants noted the importance of timely, consistent, and predictable service delivery.
Participants said that delays in approvals can have operational and financial impacts, including grounding aircraft or delaying projects.
Participants told us that:
- processing times for approvals and certificates can be long or uncertain
- delays can affect aircraft availability, business operations, and project timelines
- predictable timelines are important for planning maintenance, inspections, and operations
- service standards should be clear and consistently met
Participants suggested to:
- include accountability measures when service standards are not met
- simplify or streamline processes to reduce delays and administrative burden
Overall, participants said reliable and predictable service delivery is an important part of the fee modernization.
Theme 3: Additional Considerations
Feedback on Schedule V and VI
Participants identified several considerations for how the proposed changes could affect different parts of the aviation sector.
Participants told us that:
- impacts may vary depending on the type of operation. For example, general aviation and non-commercial aviation may be more affected than larger commercial operations
- some aviation sectors, such as amateur-built aircraft, gliding, and balloons, have unique operating models and cost structures
- certain aircraft types, such as balloons, have shorter lifecycles or different inspection requirements that could affect how fees apply
Participants suggested to:
- introduce tiered or differentiated fee structures based on the type of operation
- review whether some processes could be simplified, streamlined, or digitized
- explore delegated or alternative models to improve efficiency and reduce administrative burden
- introduce a yearly flat fee per certification project, similar to the approach used by the European Union Aviation Safety Agency (EASA), with the adjustment for the unused months once project is closed
- ensure requirements better reflect the risk and complexity of different aircraft types and operations
Overall, participants emphasized the need to consider sector differences and practical implementation.
Next steps
Comments received through this consultation will help inform the development of proposed regulations.
The next opportunity for consultation will take place when the proposed regulatory changes are pre-published in the Canada Gazette, Part I. We will notify stakeholders when the proposal is published.