Transport Canada is proposing changes to its aircraft registration fees. This document describes the context, policy rationale and analyses that informed the proposed changes.
Related acts and regulations: Aeronautics Act (R.S.C., 1985, c. A-2), Canadian Aviation Regulations (SOR/96-433)
On this page
- Executive summary
- 1.0 Purpose
- 2.0 Context
- 3.0 Overview of aircraft registration
- 4.0 Current fees
- 5.0 Cost to Transport Canada of providing aircraft registration services
- 6.0 Analyses to determine the proposed fees
- 7.0 Proposed fee changes and rationales
- 8.0 Proposed regulatory amendments
- 9.0 Proposed service standards
- 10.0 Engagement and implementation
- Appendix A: International comparison
- Appendix B: Current fee structure to proposed fee crosswalk
Executive summary
Transport Canada maintains the Canadian Civil Aircraft Register. The Register contains:
- information about aircraft owners and operators, such as name and address
- details on aircraft, like make, model, and aircraft category
- the registration mark (a series of letters) of every Canadian civil registered aircraft
As of January 2022, there are over 37,000 aircraft recorded in the Register.
In Canada, an individual who is licenced to operate an aircraft may only do so if that aircraft is registered either in Canada, in a state that is a party to the Convention on International Civil Aviation, or in a foreign state that has an agreement in force with Canada. The registration ensures that:
- Transport Canada knows the identity of the aircraft's owner and operator
- Transport Canada can communicate with the owner about critical safety issues relating to the aircraft
- aircraft operators, air traffic control units and other pilots can communicate effectively by using the aircraft registration mark as an identifier
Currently, aircraft registration fees recover approximately 29% of the estimated $1.9 million per year it costs Transport Canada to provide aircraft registration services. This means that 71% of Transport Canada's costs are paid for by taxpayers who are not the primary benefactor of the services.
Transport Canada is modernizing its aircraft registration services and fees. This involves:
- introducing fees for some services that are currently free
- increasing fees
- repealing certain fees
- adjusting low-materiality fees every year on April 1, based on the Consumer Price Index
These changes help Transport Canada recover more of the costs of providing aircraft registration services and help keep the Canadian Civil Aircraft Register up to date. Keeping the Register current would improve Transport Canada's ability to both identify aircraft and communicate with aircraft owners.
The proposed fees take the following into consideration:
- how much it costs to provide aircraft registration services
- how the services benefit clients
- what other countries charge for the same or similar services
- the economic context of aircraft owners in Canada
These proposed changes would have those who benefit directly from services, which are the aircraft owners and operators, pay a greater share of the costs. The proposed modernized aircraft registration fees would come into force in the spring of 2024. This initiative is part of Transport Canada's broader plan to modernize transportation laws, regulations, services, and fees.
1.0 Purpose
Transport Canada (TC) is proposing to modernize its aircraft registration fees. This fee proposal describes the proposed changes, as well as the context, rationale, and analyses that were considered in developing the proposal.
TC proposes:
- introducing fees for some services that are currently free
- increasing fees
- repealing certain fees
- adjusting low-materiality fees every year on April 1, based on the Consumer Price Index
This fee proposal is a tool for engagement with aircraft registration clients and the general public. Comments on this fee proposal can be submitted on TC's Let's Talk Transportation webpage.
TC will consider feedback received on this fee proposal and will consult again with Canadians when it pre-publishes the proposed regulations in the Canada Gazette, Part I, expected in the spring of 2023. TC aims to have modernized fees for aircraft registration come into force in the spring of 2024.
2.0 Context
Some TC services have been provided to individuals and industry free of charge, while fees for other services have not been updated in over 20 years and therefore do not reflect the real cost to TC to deliver those services. As a result, Canadian taxpayers are currently bearing a high proportion of the costs of providing these services to TC clients.
The Service Fees Act (SFA) was enacted in 2017 and provides an updated legal framework governing fee setting. The SFA represents the Government's commitment to modernizing its services and delivering value to Canadians. The SFA applies to all TC fees that currently exist and those that TC plans to introduce.
Over the next few years, TC will:
- introduce new fees
- increase existing fees
- simplify fee structures
Fee modernization will be achieved primarily through regulatory changes. It is part of a broader plan to:
- modernize laws, regulations, rules, and standards
- ensure TC continues to uphold safety, security, and environmental objectives
- ensure TC can continue to support innovation in the transportation sector
The Canadian Aviation Regulations (CARs) are the regulatory requirements that support the Minister's responsibility under the Aeronautics Act to implement and enforce aviation safety requirements. The aircraft registration fees listed in the CARs, excluding remotely piloted aircraft system registrations, came into force in 1996 and have not yet been updated since. These fees are out of date and do not reflect the increased costs to provide these services. Currently, TC's fees for aircraft registration services recover 29% of the total cost to the department of providing these services and the remaining 71% of the total cost is paid by taxpayers. These proposed changes would have those who benefit directly from services, which are aircraft owners and operators, pay a greater share of the costs.
3.0 Overview of aircraft registration
TC's Civil Aviation directorate administers the aircraft registration program in Canada. The program is responsible for maintaining the Canadian Civil Aircraft Register (Register) which keeps records on:
- who has custody and control of a particular aircraft
- the aircraft's registration mark
- the information on the aircraft identification plate, including manufacturer information and the aircraft serial number
- other information, such as the aircrafts' intended purpose, base of operation and maximum weight
TC also maintains the Register, which involves:
- registering imported and Canadian-built aircraft
- re-registering aircraft where there is a transfer of custody and control
- removing aircraft particulars when an aircraft is destroyed, withdrawn from service, or exported to another civil aviation authority
- assigning a registration mark to an aircraft
- keeping aircraft, owner, operator, and registration mark information in the Register up-to-date
These activities are foundational regulatory requirements that support the Minister's powers and responsibilities under the Aeronautics Act in relation to aviation safety. The program fulfills Canada's requirements under the International Civil Aviation Organization's (ICAO) Convention on International Civil Aviation to register aircraft and have them display the appropriate nationality and registration marks.
Aircraft registration helps to promote the safety of the individuals aboard that aircraft, the safety of other users of the airspace, and even the safety of individuals and property on the ground through identification and communication with aircraft owners. Aircraft registration facilitates communication between TC and the operator of the aircraft, such as communicating mandatory maintenance or inspection requirements, and component replacement. The registration mark identifies the aircraft to support communications between the aircraft, air traffic control and with other pilots. The mark also assists in search and rescue activities in cases of emergencies or accidents.
The Canadian Aviation Regulations (CARs) are the regulatory requirements that support the Minister's powers and responsibilities under the Aeronautics Act in relation to aviation safety. Subpart 2 under Part II of the CARs outlines the current regulatory requirements for aircraft marking and registration. In Canada, an individual licenced to operate an aircraft may only do so if the aircraft is registered either in Canada or registered in a state that is a party to the Convention on International Civil Aviation, in other words a contracting state or a foreign state that has an agreement in force with Canada. Aircraft owners are not subject to registration fees in more than one jurisdiction at the same time for a particular aircraft since aircraft can only be recorded in one register at a time.
Aircraft registrations are categorized as private, commercial, or state according to the applicants' statements of intended purpose. State aircraft are those owned by and only used in the service of Canadian federal, provincial, and municipal governments. Commercial aircraft are those operated for aerial work, air taxi operations, commuter operations, or airlines operations commercial air services, and aeroplanes or helicopters to be operated pursuant to a flight training unit operator certificate. Private aircraft are those that do not fall within the other two aircraft registration types.
The Register also contains the registration mark assigned to an aircraft, which are a combination of letters issued by a state. The registration mark is painted on the exterior of an aircraft for ease of visibility. All aircraft operating in Canada must have a unique mark, of a specific size, placed in specific locations on the aircraft, unless special authorization has been obtained from the Minister.
Simply put, an aircraft registration records and links the aircraft, the aircraft owner, and the registration mark together in the Register.
TC also intends to modernize its service delivery for aircraft registration services by improving the online request platform, which can be expected to simplify the registration process as well as increase the accuracy of requests received.
4.0 Current fees
Subsection 4.4(2) of the Aeronautics Act provides the Governor in Council the authority to impose charges for the use of any facility or service provided by or on behalf of the Minister, for or in respect of any aircraft, as well as in respect of any action related to the issuance, renewal, amendment, or endorsement of aviation documents. The Canadian Aviation Regulations (CARs) lists the current general and aircraft registration fees, in Part I, Subpart 4, in Schedule I and Schedule II, which are as follows:
| Schedule I - General | Current fee |
|---|---|
| Replacement of a mutilated, lost or destroyed Canadian aviation document | $35 |
| Schedule II - Aircraft Registration | Current fee |
|---|---|
| Reservation of a registration mark | $45 |
| Issuance or reservation of a special registration mark | $140 |
| Issuance of a certificate of registration, in respect of a provisional or temporary registration | $65 |
| Issuance of a certificate of registration, in respect of a continuing registration | $110 |
| Issuance of a certificate of registration, in respect of an amendment to a certificate, other than a change of address | $65 |
5.0 Cost to Transport Canada of providing aircraft registration services
Costing for cost recovery purposes requires the calculation of the “full cost” to TC of delivering aircraft registration activities. In accordance with the Financial Administration Act and associated directives, a fee should not exceed the “full cost” to provide the service.
A full cost estimate comprises all relevant resource costs incurred to provide an activity, including direct and indirect costs. More specifically, the aircraft registration activities cost estimates include:
- employee salaries and benefits
- operating and maintenance costs
- development of IT systems
- program support, internal services, and office space
TC developed a costing model that captures these cost elements and applies principles of activity-based costing to assign costs to activities provided by the department based on their use of resources. The cost to deliver aircraft registration activities are estimates which primarily reflect historical program delivery expenditures for TC Civil Aviation, with future-oriented adjustments factored in, such as the expected efficiencies to be gained from a modernized aircraft registration service platform.
The estimated cost to process a single transaction depends on the type of service and the effort it takes to handle the request. Most of TC's aircraft registration services cost between $200 and $600 to provide. For example, it costs approximately $242 to reserve a registration mark based on the average time it takes TC to complete the request. At the high end, the most time consuming and complex transaction is processing a request for authorization of an alternate registration mark size or location which costs approximately $965.
The estimated per-unit cost to handle a single aircraft registration service transaction is the maximum price that TC could charge. However, as described in the following section, TC also took additional considerations into account when proposing the fees.
6.0 Analyses to determine the proposed fees
In addition to the cost to TC of providing aircraft registration services, TC also conducted the following analyses to determine the proposed fees:
- Public-private benefit assessment: TC considered the level of benefit that clients receive from aircraft registration services, beyond the benefit received by the Canadian public generally
- International comparisons: TC examined how much other countries charge, if anything, for the same or similar aircraft registration services
- Stakeholder impact considerations: TC examined the economic context of the Canadian aviation industry in which the aircraft owners operate, as well as their unique circumstances
- COVID-19 context: TC considered the impact the COVID-19 pandemic has had on aircraft registration stakeholders
6.1 Public-private benefit assessment
Many of TC's services provide both public and private benefits. For services that provide a purely public benefit or a purely private benefit, cost recovery rates of 0% and 100% respectively, may be appropriate. For services that provide a mix of private and public benefits, establishing a cost recovery rate is more complex. In these cases, the amount TC charges reflects the extent to which the service provides a private benefit to the client, among other factors described in this proposal.
For aircraft registration services, a public-private assessment was done using the Government of Canada's Public-Private Benefit Assessment tool, which was developed by the Treasury Board of Canada Secretariat. This tool is used to estimate the extent to which aircraft registration services benefit clients beyond the benefits attributed to the general public. Some registered owners benefit from commercial activity or market access which allows them to use the aircraft to generate income or to use their aircraft internationally. Registration is one of the requirements for operating an aircraft internationally. Others can enjoy their aircraft, once registered, for personal purposes. All registered owners also benefit from the Register facilitating and enhancing communications, be it between TC and the owners or between the aircraft operators themselves.
The tool estimated that approximately 80% of the benefits from TC's aircraft registration services accrue to clients, such as the companies, organizations and individuals who register their aircraft.
The remaining benefits accrue to the broader public, through safer air transportation since registration enables regulation and enforcement.
The 80% private benefit helps to establish what percentage of the cost TC may be able to recover for the aircraft registration services it provides.
6.2 International comparison
TC conducted an international comparison to inform the proposed aircraft registration fees. For this comparison, TC examined jurisdictions with a similar level of economic development to Canada and those which have similar regulatory approaches to aircraft registration, namely the United Kingdom (UK), United States (US), Australia and New Zealand. Some aspects of these countries' services and fees do differ from those of Canada, making direct comparisons of fees between countries challenging. The US' Federal Aviation Administration (FAA) operations are mainly funded through the Aviation Trust FundFootnote 1, which collects revenues through aviation-related excise taxes, therefore the FAA only charges nominal fees for offering similar services. Other differing aspects include:
- the scope of services offered: the UK offers expedited services for a fee
- validity periods: the US certificate of registrations must be renewed every three years while the New Zealand registrations are subject to an annual maintenance fee
- the fee structures: Australia charges an hourly rate for a special registration mark configuration
Furthermore, in some cases, information from other countries for certain services was not readily available. However, there were sufficient similarities amongst these countries' services to draw informative comparisons between their fee regimes and the current and proposed Canadian fee approach for aircraft registration.
Some brief and notable examples of international comparisons made are:
- Canada's proposed fee for a continuing certificate of registration ($400 and $450) is above the range of that of the UK (CAD $129 to $259), Australia (CAD $125) and New Zealand (CAD $261)
- Canada's proposed registration mark related fees ($140 and $270) are above Australia (CAD $63), generally in the range of New Zealand (CAD $0 to $174) and below the UK (CAD $0 to $538)
Please refer to Appendix A: International Comparison for a complete and detailed comparison of Canada's current and proposed fees to the four countries analyzed.
6.3 Stakeholder impact considerations
In developing the fees put forward in this proposal, TC considered the diverse range of aircraft registration stakeholders and interested parties, including considering the context in which they operate.
A person or organization that purchases an aircraft must obtain a continuing certificate of registration from TC. In other words, they must become a registered owner, and pay a fee. When an aircraft is imported to Canada, the owner must obtain a provisional certificate of registration to fly the aircraft to Canada in addition to obtaining a continuing certificate of registration from TC after the aircraft has arrived. The owner may choose to reserve a random, system-generated registration mark assigned in advance of registration, or to reserve a particular registration mark in advance of, or at the time of, registration. Each of these registration services have fees. The alternative to paying for reserving a registration mark is to accept a system-generated mark at the time of application for registration, which is free. Furthermore, to operate an aircraft in Canada, the owner is also required to obtain and pay TC for a flight authority document that confirms an aircraft's fitness for flight. Flight authorities are not fees listed in schedule II of CAR 104, they are listed in schedule VI which is related to the maintenance and manufacturing of aircraft.
The following sections provide an overview of currently registered aircraft, as well as key stakeholder groups and interested parties.
6.3.1 Overview of registered aircraft
As of January 2022, over 37,000 aircraft, including aeroplanes, helicopters, balloons, gliders, and gyroplanes, are recorded in the Canadian Civil Aircraft Register. Private aircraft, which include corporate and business aircraft, represent 80% of the register, 19% are commercial aircraft, and 1% are state aircraft which are operated by either municipal, provincial, or federal governments, including policing agencies.
The number of initial aircraft registrations declined in the 2010s compared with previous decades. Between 2000 and 2005, the Register grew at an average rate of 400 aircraft per year, while between 2015 and 2021, the Register grew at an average rate of 94 aircraft per year. Most TC aircraft registration fees apply to aircraft that are registered for the first time.
Private aircraft
Private aircraft registrations are concentrated in Quebec, Ontario, Alberta, and British Columbia. The most common private aircraft models in the Register are the Cessna 172, Piper PA-28 and Cessna 150. The Register contains more than 1,000 of each of these models. The purchase price of these aircraft is typically from $25,000 to well over $500,000 for used and new aircraft. The average age of a private aircraft was 39 years at the end of 2020Footnote 2.
Between 2011 and 2020, the most common private registered aircraft manufactured in Canada were the Bombardier Model BD-700-1A10, the Bell Model 429, the Dehavilland Model DHC-8-402, the Bell Model 412EP, the Viking Model DHC-6 SERIES 400, the Bombardier Model BD-700-1A11, the Bombardier Model CL-600-2B16 and the Bell Model 505. Furthermore, mini planes are also among the most common privately registered aircraft, reflecting an increasing trend of low-cost “powered parachute” ultra-light aircraft registrations, particularly in Quebec.
Owners of privately registered aircraft include a diverse mix of individuals and organizations. Some individuals fly relatively low value aircraft in a very small area for recreation, others are individuals or organizations who operate sophisticated luxury business jets around the globe for business purposes.
Commercial aircraft
Commercial aircraft registrations are concentrated in Quebec, Ontario, Alberta, and British Columbia. The most common commercial aircraft models in the Register are the Cessna 172, the Aerospatiale AS350 helicopter and the Bell 206 helicopter with purchase prices between $60,000 USD and $2 million USD for new and used aircraft. These are followed by two types of airliners, the De Havilland Dash 8 and the Boeing 737. The purchase price of these aircraft is typically between $3 million to $135 million USD for new and used aircraft. The average age of commercial registered aircraft is 33 years. Over the past 10 years, the most common new commercial registrations were issued for the Aerospatiale Model AS350 B3, the Dehavilland Model DHC-8-402, the Boeing Model 737-8K5, the Aerospatiale Model AS 350 B-2 and the Cessna Model 172S.
Owners of commercial registered aircraft include:
- flight training units, which include flight schools, flight colleges, flying clubs, and universities, all of which conduct flight training for the general public
- aerial work operators, who engage in aerial advertising, aerial construction, aerial photography, and aerial surveying
- air taxi operators, who operate aircraft that seat nine or fewer passengers, and conduct either unscheduled or chartered flights for workers, residents, or vacationers, travelling to remote locations such as to northern and First Nations communities
- commuter operations, which include aircraft carrying up to 19 passengers
- airline operators, who operate aircraft that seat 20 or more passengers
- aircraft manufacturers for reasons related to manufacturing and exporting
State aircraft
Most state aircraft are used by federal departments such as Transport Canada and the Royal Canadian Mounted Police. The most common types of registered state aircraft between 2011 and 2020 were the Bell Model 429, the Pilatus Model PC-12/47E, the Bell Model 412EP and the Airbus Helicopters Model AS 350 B3. Table 2 is a summary of all aircraft registration types by aircraft type.
| Registration type | Aeroplane | Helicopter | Other | Totals |
|---|---|---|---|---|
| Private | 27,102 | 1,071 | 1,440 | 29,613 |
| Commercial | 5,437 | 1,747 | 16 | 7,200 |
| State | 145 | 67 | 0 | 212 |
| All types | 32,684 | 2,885 | 1,456 | 37,025 |
6.3.2 Expected impact of aircraft registration fees
TC is mindful that aircraft operators pay taxes and fees to various levels of government and that federal initiatives, such as the reduction of air sector greenhouse gas emissions, have financial impacts on airline operators. The proposed aircraft registration fees, ranging from $70 to $650, are non-recurring and minimal relative to the costs associated with purchasing and operating an aircraft, which include at a minimum, the purchasing or financing, insurance, fuel, and maintenance costs.
Overall, TC does not expect the proposed changes to aircraft registration fees to have a discernible impact on the intentions to purchase aircraft for private, commercial, or state use purposes, nor on the continued operation of already registered aircraft.
TC's plans to engage stakeholders and seek their feedback on this fee proposal are outlined in the engagement and implementation section of this document.
6.4 COVID-19 context
TC recognizes the significant impact that the COVID-19 pandemic has had on the aviation industry. The ICAO published a report in March 2021 that confirmed that air passenger traffic suffered a dramatic 60% drop during 2020, bringing air travel totals back to 2003 levelsFootnote 3. As a result, Canadian passenger airlines' cash flows declined to near-zero, forcing them to park planes and lay-off employeesNote de bas de page 4.
TC is closely monitoring the recovery of the aviation industry and is taking the economic impacts and challenges into consideration, as it modernizes its fees. TC is sensitive to the financial and operational challenges faced by its clients, including aircraft owners and operators. Therefore, TC has delayed fee modernization plans for several aviation programs and will allow more time for improvement to economic conditions before implementing changes to fees affecting the aviation industry. TC is proposing that modernized Civil Aviation aircraft registration fees come into force in the spring of 2024, which should allow time for the economic circumstances of impacted aircraft operators to improve before the proposed fees would come into effect.
7.0 Proposed fee changes and rationales
Considering the factors described in the previous section, TC is proposing to update the fees listed in the following table. These proposed fees would all be payable upfront, at the time a client requests a service. The proposed fees better reflect the cost to TC to provide these services and ensure that those who benefit directly from the services pay a greater share of the costs. The table below provides rationales for the proposed fee updates. The current fees and proposed fees are included for comparative purposes.
| Activities | Current fee | Proposed fee | Additional context and rationale for proposed changes |
|---|---|---|---|
| 1. Reserve a registration mark | $45 | $140 |
|
| 2. Reserve a particular registration mark | $140 | $270 |
|
| 3. Renew a registration mark reservation before it expires | $140 | $70 |
|
| 4. Authorize an alternate registration mark size, location or variance from the specifications for registration marks | None | $500 |
|
| 5. Authorize the operation of an aircraft in Canada that does not display a registration mark | None | $200 |
|
| 6. Change a registration mark after the issuance of a continuing certificate of registration | None | $650 |
|
| 7. Issue a provisional certificate of registration | $65 | $200 |
|
| 8. Provide a blank interim certificate of registration | None | $109 |
|
| 9. Issue an initial continuing certificate of registration | $110 | $450 |
|
| 10. Issue a continuing certificate of registration for a transfer of custody and control | $110 | $400 |
|
| 11. Replace a mutilated, lost or destroyed continuing certificate of registration | $35 | $109 |
|
| Service or activity | Current fee | Proposed fee | Additional context and rationale for proposed changes |
|---|---|---|---|
| 1. Issuance of a certificate of registration, in respect of a temporary registration | $65 | None |
|
| 2. Amendment to a certificate of registration, other than a change of address | $65 | None |
|
The current aircraft registration fees have remained the same for over 20 years. The fees will be adjusted every year on April 1, as required by section 17 of the SFA, based on the Consumer Price Index published by Statistics Canada. TC is proposing that all low-materiality aircraft registration fees, as defined in the Low-materiality Fees Regulations, which are currently exempt from section 17 of the SFA, would also be adjusted every year on April 1, based on the Consumer Price Index published by Statistics Canada.
8.0 Proposed regulatory amendments
As discussed, TC is proposing regulatory amendments to Part I, Subpart 4, Schedule II, of the CARs that will add new fees, update existing fees and repeal some fees. In addition to modernizing its fees, TC is also conducting a regulatory review to modernize the CARs as part of a separate initiative. Primary goals of this regulatory review are to remove irritants and make the regulations clearer to better respond to client needs, while maintaining a high level of aviation safety. The proposed services and fees will also align to updates being made as part of the regulatory modernization work, particularly to CAR Part II.
TC is proposing to embed within the fee regulations an annual adjustment clause which will ensure that aircraft registration fees keep pace with the cost of inflation and will also support the financial sustainability of the aircraft registration program.
9.0 Proposed service standards
The SFA requires:
- TC to establish and report annually on how often service standards are met
- TC to issue a partial refund when service standards are not met
TC's departmental remission policy took effect April 1, 2021. This policy explains that TC would issue a remission if a service standard is missed by more than 25%.
Service standards publicly state the level of service a client can expect, often in terms of how long it should take the department to provide a particular service. The proposed service standards for aircraft registration are based on the typical length of time it takes to fulfill a service request and were developed with consideration given to planned future service delivery improvements. The current fees and proposed service standards are included in the table below for comparative purposes.
As part of this fee proposal, TC is proposing to:
- update and clarify the service standards for existing activities
- create service standards for activities with new fees
| Activities | Current service standard | Proposed service standard |
|---|---|---|
| 1. Reserve a registration mark | 10 working days. Actual processing times can vary depending on the complexity and the completeness of the request. | Issue mark reservation letter within 10 business days after receipt of a complete application. |
| 2. Reserve a particular registration mark | 10 working days. Actual processing times can vary depending on the complexity and the completeness of the request. | Issue mark reservation letter within 10 business days after receipt of a complete application. |
| 3. Renew a registration mark reservation before it expires | 10 working days. Actual processing times can vary depending on the complexity and the completeness of the request. | Issue mark reservation letter within 5 business days after receipt of a complete application. |
| 4. Authorize an alternate registration mark size, location or variance from the specifications for registration marks | None published. | Issue mark reservation letter within 20 business days after receipt of a complete application. |
| 5. Authorize the operation of an aircraft in Canada that does not display a registration mark | None published. | Issue authorization letter within 20 business days after receipt of a complete application. |
| 6. Change registration mark after the issuance of a continuing certificate of registration | None published. | Issue continuing certificate of registration within 30 business days after receipt of a complete application. |
| 7. Issue a provisional certificate of registration | 60 working days. Actual processing times can vary depending on the complexity and completeness of the request. | Issue provisional certificate of registration within 10 business days after receipt of a complete application. |
| 8. Provide a blank interim certificate of registration | None published. | Provide blank interim certificate of registration within 7 business days after receipt of a complete application. |
| 9. Issue an initial continuing certificate of registration |
For a domestic aircraft: 60 working days. For an imported aircraft: 10 working days. Actual processing times can vary depending on the complexity and completeness of the request. |
Issue continuing certificate of registration within 10 business days after receipt of a complete application. |
| 10. Issue a continuing certificate of registration for a transfer of custody and control |
For a domestic aircraft: 60 working days. Actual processing times can vary depending on the complexity and completeness of the request. |
Issue continuing certificate of registration within 60 business days after receipt of a complete application. |
| 11. Replace a mutilated, lost or destroyed continuing certificate of registration | 10 working days. Actual processing times can vary depending on the complexity and completeness of the request. | Issue continuing certificate of registration within 20 business days after receipt of a complete application. |
| Activities | Current service standard | Proposed service standard |
|---|---|---|
| 1. Amendment to a certificate of registration, other than a change of address | 60 working days. Actual processing times can vary depending on the complexity and completeness of the request. | Issue continuing certificate of registration within 60 business days after receipt of a complete application. |
| 2. Amendment to a certificate of registration for a change of address | None published. | Issue continuing certificate of registration within 60 business days after receipt of a complete application. |
| 3. Cancellation of registration | 3 working days. | Issue de-registration notice within 5 business days after receipt of a complete application. |
| 4. Recording an Irrevocable De-Registration and Export Request Authorization (IDERA), not associated to the continuing certificate of registration application | None published. | Record an Irrevocable De-Registration and Export Request Authorization (IDERA) submitted by the registered owner of an aircraft with an existing continuing certificate of registration within 10 business days after receipt of a complete application. An IDERA can only be attached to a registered aircraft. |
| 5. Extension of a CAR 202 lease | None published. | Issue lease extension letter within 30 business days after receipt of lease extension notification. |
In May 2019, TC consulted stakeholders seeking feedback on regulatory irritants in Part II of the Canadian Aviation Regulations. The stakeholders had comments about the processing time for continuing certificates of registration. More specifically, there were concerns about the 60 business day wait to receive the continuing certificate of registration. As seen in the table above (#9 of Table 5), TC has revised this service standard for applications for initial registrations down to 10 business days. It should be noted that the 60 business day service standard has been maintained for transfers of custody and control as new owners can operate their aircraft for 90 calendar days under an interim certificate of registration. If the previous owner cannot provide the new owner with a blank interim certificate, the new owner can request one from TC. The interim certificate of registration's validity period aligns with TC's processing time for a continuing certificate of registration, in cases of a transfer of custody and control, which would allow the client to use their aircraft while TC is processing the request.
10.0 Engagement and implementation
TC's Fee Modernization initiative is a multi-year undertaking, and TC is engaging stakeholders to seek their feedback throughout the process. TC has presented its Fee Modernization initiative at various plenary sessions of the Canadian Aviation Regulation Advisory Council (CARAC) meetings since 2018.
In February 2022, TC held a preliminary engagement session to inform stakeholder associations of TC's plans to amend and introduce aircraft registration service fees. The main consideration raised at the session was not about the proposed fee increases, but about TC needing to meet its service standards and providing certainty in service delivery to its clients.
This fee proposal will be posted on TC's Let's Talk Transportation webpage in June 2022, where it will be available for stakeholder and public comment for 60 days. TC intends to notify stakeholders by email that this fee proposal is available for comment. As well, as part of the consultations, presentations and discussions on this fee proposal are scheduled to take place at the national CARAC meeting in 2022 and will include further opportunities for feedback and discussion.
Following consultations on this fee proposal, TC will publish a “What We Heard” report, which will summarize the feedback received during the consultation period and outline next steps. Proposed regulations would then be pre-published in the Canada Gazette, Part I, which is currently planned for the spring of 2023. At that stage, stakeholders and the public will have an additional opportunity to provide feedback to TC. Once that final review is complete, the proposed fees and regulatory amendments will be published in Canada Gazette, Part II, currently planned for the spring of 2024.
TC will publish guidance material for both stakeholders and employees so that stakeholders can clearly understand how and when the fees would be applied, and to ensure that the new and updated fees are applied consistently across Canada. Clients who submit requests for services prior to the date of implementation of the new and updated fees would be charged the current fees. Clients who submit requests for services after the coming into force date would be charged the modernized fees.
All fees would be adjusted every year on April 1, based on the Consumer Price Index published by Statistics Canada. They will be published on the TC website and TC will report on its fees in its annual Fees Report, tabled in Parliament, and posted on TC's website.
Appendix A: International comparison
Note: Conversions to Canadian dollars are based on exchange rates published by the Bank of Canada on February 28, 2022.
| Canada's services | Canada Current fee | Canada New fee | UK servicesFootnote 5 | UK fees | US servicesFootnote 6 | US fees | Australia (Aus) servicesFootnote 7 | Aus. fees | New Zealand (NZ) servicesFootnote 8 | NZ fees |
|---|---|---|---|---|---|---|---|---|---|---|
| Reserve a registration mark (12 month validity) | $45 | $140 | Reserve a UK Registration Mark (6 month validity) | None | Reserve a registration number (12 month validity) | $13 ($10 USD) | Reservation of a registration mark (12 month validity) | $60 ($65 AUD) | Reservation of a registration mark (24 month validity) | None |
| Reserve a particular registration mark (12 month validity) | $140 | $270 | Reservation of an out-of-sequence mark (6 month validity) | $269 (£158) | Reservation or assignment of a special registration number (12 month validity) | $13 ($10 USD) | Information not readily available | Not known | Reservation or Allocation of a particular Registration Mark (24 month validity) | $166 ($194 NZD) |
| Renew a registration mark reservation before it expires (12 month validity) | $140 | $70 | Extend reservation | None | Renew reservation | $13 ($10 USD) | Extensions to reservations aren't permitted | None | Information not readily available | None |
| Authorize an alternate registration mark size, location or variance from the specifications for registration marks | None | $500 | Information not readily available | Not known | Information not readily available | Not known | Giving a direction about where markings are to be placed on an aircraft with a special configuration | $147 per hour ($160 AUD per hour) |
Information not readily available | Not known |
| Authorize operation of an aircraft without displaying registration marks | None | $200 | Information not readily available | Not known | Information not readily available | Not known | Information not readily available | Not known | Information not readily available | Not known |
| Change registration mark after the issuance of continuing certificate of registration (Original charge was the Special registration mark fee and Continuing certificate of registration fee) |
$140 + $110 = $250 | $650 |
Changes of registration mark:
|
$124 (£73) or $249 (£146) | Aircraft N-Number Change (Special registration number fee and number change fee) |
$25 ($20 USD) | Change of a registration mark | $120 ($130 AUD) | Change of a registration mark (Certificate of registration fee and Airworthiness certificate fee) |
$254 + $244 per hour or ($296 + $284 per hour NZD) |
| Issue a temporary certificate of registration | $65 | Will no longer offer service | Information not readily available | Not known | Information not readily available | Not known | Information not readily available | Not known | Information not readily available | Not known |
| Issue a provisional certificate of registration | $65 | $200 | CAA approval to fly with an unregistered aircraft | None | Dealer's Aircraft Registration Certificate | $13 ($10 USD) | No requirement to temporarily register if dealer's marks are used | None | Special flight permit does not require an accompanying registration | None |
| Provide a blank interim certificate of registration (They are valid for 90 calendar days) |
None | $109 | Information not readily available | Not known | Information not readily available | Not known | Information not readily available | Not known | Information not readily available | Not known |
(They are valid until suspension or cancellation) |
$110 | $450 or $400 |
Certificate of registration of an aircraft
(They are valid until suspension or cancellation) |
$124 (£73) or $249 (£146)) | Certificate of Aircraft Registration (Must renew every 3 years, same fee) |
$6 ($5 USD) | Registration of an aircraft (They are valid until suspension or cancellation) |
$120 ($130 AUD) |
|
$254 ($296 NZD) or $226 ($263 NZD) |
| Amend a certificate of registration, other than a change of address | $65 | None | Register amendments | None | Information not readily available | Not known | Change of registration details | None | Change of registration | $338 ($394 NZD) |
| Replace a mutilated, lost or destroyed continuing certificate of registration | $35 | $109 | Replacement or copy of a Certificate of Registration | $83 (£49) | Replacement Certificate of Aircraft Registration | $3 ($2 USD) | Replacement of a certificate of registration that has been lost, stolen or destroyed | $60 ($65 AUD) | Replacement certificate | $254 ($296 NZD) |
Appendix B: Current fee structure to proposed fee crosswalk
| 1996 version of CAR 104, Schedule II | 1996 Fee | Nature of change | Proposed CAR 104, Schedule II | Proposed Fee |
|---|---|---|---|---|
| Reservation of a registration mark | $45 | Amend fee | Reserve a registration mark | $140 |
| Issuance or reservation of a special registration mark | $140 | Amend fee | Reserve a particular registration mark | $270 |
| No fee listed however, the reserve special registration mark is charged to the client | $140 | Introduce fee | Renew a registration mark reservation before it expires | $70 |
| No fee listed | None | Introduce fee | Authorize an alternate registration mark size, location or variance from the specifications for registration marks | $500 |
| No fee listed | None | Introduce fee | Authorize the operation of an aircraft in Canada that does not display a registration mark | $200 |
| No fee listed | None | Introduce fee | Change a registration mark after the issuance of continuing registration | $650 |
| Issuance of a certificate of registration, in respect of a provisional registration | $65 | Amend fee | Issue a provisional certificate of registration | $200 |
| Issuance of a certificate of registration, in respect of a temporary registration | $65 | Repeal fee | Repeal | None |
| No fee listed | None | Introduce fee | Provide a blank interim certificate of registration | $109 |
| Issuance of a certificate of registration, in respect of a continuing registration | $110 | Repeal and introduce fee | Issue an initial continuing certificate of registration | $450 |
| Issuance of a certificate of registration, in respect of a continuing registration | $110 | Repeal and introduce fee | Issue a continuing certificate of registration for a transfer of custody and control | $400 |
| Issuance of a certificate of registration, in respect of an amendment to a certificate, other than a change of address | $65 | Repeal fee | Repeal | None |
| 1996 version of CAR 104, Schedule I | 1996 Fee | Nature of Change | Proposed CAR 104, Schedule II | Proposed Fee |
|---|---|---|---|---|
| Replacement of a mutilated, lost or destroyed Canadian aviation document | $35 | Amend existing fee to exclude certificates of registration and introduce fee in Schedule II | Replace a mutilated, lost or destroyed continuing certificate of registration | $109 |