The new Air Navigation Order (ANO) 2016 comes into force today. It provides the foundation for a simpler and more proportionate approach to the regulation of many GA activities that fall under national (and not European) regulation.

You'll notice a substantially different structure to that of the ANO 2009. The different drivers for change, most importantly the General Aviation ANO review, have prompted us to take a new approach to its layout. We believe that this will result in a clearer and easier to understand document and hope the new structure will help pilots (and others involved in the operation of non-EASA aircraft - the vast majority of them being involved in GA) find the information that they need more easily.

Scope, applicability and key definitions are now set out at the front. Derogations, or exceptions as they are known in UK law, that apply to a number of GA activities have also been moved close to the front. Previously many of these provisions were towards the back.

Some terms have also been changed to match those used by EASA and help make rules clearer to understand while sections of the Order have been organised to follow regulatory functions, like airworthiness, operations and licensing.

GA pilots and those involved in the operation of non-EASA aircraft might care to review the following sections: 

Key definitions and exceptions

Part 1 includes key definitions and exceptions including those that cover cost sharing, charity flights and glider towing. The cost sharing provision continues to be aligned with EASA rules (up to six people sharing the cost rather than four) although this will be addressed in the future.
The term 'aerial work' has been replaced with 'commercial operation' throughout the ANO to make it easier to distinguish between non-commercial GA operations and commercial or public transport.


Part 4 sets out the legal basis for the airworthiness of non-EASA aircraft.

Most of the continuing airworthiness requirements in the ANO in this area apply to non-EASA aircraft that hold a certificate of airworthiness. Some airworthiness procedures have been aligned with Part-M, so pilot owners conducting maintenance on aircraft with a certificate of airworthiness must now sign a certificate of release to service (CRS). 

The legal provision to maintain a non-EASA aircraft up to 2,730 kgs with a certificate of airworthiness in accordance with a 'self-declared' maintenance programme has also been incorporated, in line with EASA's Part-M Light, which is expected next year.

Aircraft on national permits to fly must continue to comply with the policy and requirements of the organisation that issued the certificate of validity (whether that is the CAA or an approved sporting organisation). 
Article 42 (Limitations of permits to fly) has been simplified. Going forward the CAA will publish standardised policy via general permission under the article which addresses the use of permit aircraft for commercial operations and/or for hire.

E conditions, a major GA policy initiative to allow flight by experimental aircraft, has been incorporated into the new ANO. A conditions has also been updated such that it can be used by aircraft on a national permit to fly in some circumstances. 

Operational requirements

Part 5 includes a new chapter that covers the basic operational requirements for all non-EASA aircraft and sets out the responsibilities and obligations of the pilot in command. It contains requirements for all flights under the ANO, except public transport operations which are now covered in Chapter 7 of Part 5. Although there is nothing to make life substantially different for a GA pilot an understanding of their legal responsibilities is essential, and this separation of requirements should make them easier to understand.

National flight crew licensing

Part 6 covers the legal basis for national (rather than EASA) flight crew licensing, including the medical self-declaration system for flying non-EASA aircraft. Detailed licensing requirements are included in Schedule 8.

Document and records

Part 9 addresses documents and records. There are a few articles at the start, for example pilot and aircraft logbooks, technical logs etc, which GA pilots should be familiar with. Document carriage requirements are in Schedule 10.

More definitions

Schedule 1 sets out definitions other than 'in-flight', 'operator', 'aerodrome traffic zone', 'public transport' and 'commercial operation' which are included in Part 1, Chapter 1.

Special conditions

Schedule 3 includes A, B and E conditions, the special conditions that aircraft may fly under without necessarily having a valid national permit to fly or certificate of airworthiness.  

Operational equipage

Schedule 5 covers the new operational equipage requirements for non-EASA aircraft on operations other than public transport. There has not been any increase in actual requirements over the ANO 2009 but they are set out in a simpler six page format. The use of the term 'flying machine' is used as shorthand for 'aeroplane, helicopter, gyroplane or SLMG'. 

Airworthiness records

Schedule 7 sets out the specifications for airworthiness records like aircraft, engine logbooks. They have been written with some of the Part-M wording, but there is also a 'grandfathering provision' such that any existing logbooks that complied with article 34 and Schedule 6 of the ANO 2009 may continue to be used.

The specifications for the 'operator's technical log' only applies to aircraft with a certificate of airworthiness used for commercial or public transport operations.

Licence privileges

Schedule 8 is important for GA pilots flying non-EASA aircraft as it sets out the licence privileges of non-EASA licences, the ratings that may be attached to them and the means of revalidating them. GA pilots with non-EASA licences should look at this schedule in detail:

  • Revalidation and renewal of licences other than the NPPL is set out in a clearer format in Part C. For the NPPL (A), the existing table remains the same. One change that holders of older UK licences may notice is the removal of the terms 'certificate of test/experience'. Generally speaking this concept is being removed from the ANO, however an exemption has been issued in ORS4 such that holders of a UK PPL with a microlight or SLMG class rating that was issued before 1st February 2008 may continue to use the old '5 hours in 13 months' arrangement if they wish. 
  • Revalidation of ratings have aligned with the Part-FCL approach. If a rating is  revalidated within the last three months of its validity period, the next validity period begins from the end of the existing one. When revalidating single engine piston class ratings by experience, the revalidation sign-off may be done as soon as the relevant experience has been gained.
  • The previous UK PPL and NPPL visibility minima have been removed. These licence holders are now permitted to fly under VFR or Special VFR minima, as permitted by the European rules of the Air. The minimum visibility for take-off or landing for IMC rating holders has been reduced from 1800 m to 1500 m.
  • National instructor ratings are now referred to as 'Flight instructor' and 'Flight instructor (restricted)' certificates. They are all valid for 36 months, which aligns with EASA. This replaces the terminology 'flying instructor' and 'assistant flying instructor'. Although the terms and validity periods have changed, the privileges and requirements to obtain them remain the same.

Document carriage

Schedule 10 covers document carriage requirements. For non-EASA aircraft on operations other than public transport, there are no document carriage requirements within the UK. A list has been included for those flying outside the UK.


Exemptions from the new ANO have been issued to correct the definition of controlled airspace and the requirement to consult an aero medical examiner if incapacitated by illness or injury for more than 21 days.

Speakers' corner

Ed Bellamy is a General Aviation Policy Officer at the CAA. He will be speaking about the revised ANO at the LAA Sywell Rally 2016 on Friday 2 September (3pm) and Saturday 3 September (2pm).


Yann AUBRY 4 years ago / Reply

Hello,I have red almost all the new version of ANO 2016 and associated schedules (not only for my pleasure) to find any change that could impact EASA aircraft.Do not hesitate to correct me if I'm wrong, but my conclusion is the structure of the document has been clarified and some provision of old ANO 20009 which have been omitted, but there is for EASA Aircraft no change of the regulation text ?

Ed Bellamy 4 years ago

- For the most part the regulation of EASA aircraft now sits under the relevant European regulation rather than the ANO 2016. There have been no changes to the regulation of EASA aircraft as a result of the new ANO, however some elements to the new ANO reflect the fact that new pieces of European regulation (such as Part-NCO) are now in force for EASA aircraft and therefore the ANO has been disapplied in the relevant areas.

ian francis hudson 4 years ago / Reply

Hello could you please advise if abusedrunkeness on an aircraft is triable either way under the Air Navigation Order 2016 and the maximum penalties at the Magistrates and Crown Courtif triable either way i mean The reason for this is that i simply cannot find it in the Order.Thank you.

Ed Bellamy 4 years ago

- It is an offence under Article 242 the ANO to be drunk on an aircraft and can be either a fine and/or imprisonment up to two years. For flight crew in practice a prosecution would normally be made under The Railways and Transport Safety Act 2003 since this specifies the actual legal blood alcohol limits for those involved in aviation activities.

wang 4 years ago / Reply


Paul Mansfield 4 years ago / Reply

Maybe it's me, but at first glance this is not very simplified...Under The Air Navigation Navigation Navigation Navigation Order 2016 we have PART 1 CHAPTERS 1 2 ... PART 4 CHAPTERS 3, 4 5... but then PARTS 5 8 have CHAPTERS starting with 1 again.Then, after 12 PARTS with CHAPTERS, we switch to SCHEDULES with PARTS (eg SCHEDULE 3 PARTS 1 2 etc) ok so far...Under The Rules of the Air Regulations 2015 we continue with SCHEDULES 1 2, but with Sections (not CHAPTERS or PARTS), then under The Air Navigation (General) Regulations 2006 we have Parts 1 6, followed by Schedules 1 2.Then ... under Restriction of Flying we switch to Schedule 2 (huh?) followed by The First Schedule, The Second Schedule and then just Schedule.Finally, in The Air Navigation (Dangerous Goods) Regulations 2002, we have PARTS I VIII, followed by Schedule...Confused? ... I am!Any ideas to help clarify this?

Ed Bellamy 4 years ago

Hi Paul, it is only the Air Navigation Order 2016 that has been updated, the other Regulations in CAP 393 have remained the same, and are bound by whatever drafting conventions were in force for the CAA and DfT at the time.

Nigel Robinson 4 years ago / Reply

As a PPL I applaud the change to the medical requirements which will permit daytime, VFR pilots who only fly light aircraft in the UK (a large majority of recreational pilots) to use the declaration route rather than requiring a Class 2 medical. Please pass on my thanks to those in the CAA who made this happen.If the CAA could also find a way of keeping this option open for those flying EASA aircraft (as very many PPLs do) after 2018, then that would be even better. Thank you

ROBERT BURGESS 4 years ago / Reply

Please can you put Ed Bellamys LAA Presentation about the changes to the ANO on line. There is a lot of confusion about the new requirements for GA especially those applicable to EASA certified aircraft. It needs to be in plain English.

John Holdcroft 4 years ago / Reply

REVISED AIR NAVIGATION ORDER SCHEDULE 8Please advise how I may access Schedule 8, and also the Medical Declaration Form to allow me to fly on the basis of possessing a driving licence. Thank you.John Holdcroft

Ed Bellamy 4 years ago

Hi John - Schedule 8 is part of the ANO, which is contained within CAP 393. The medical declaration is available from our page on medical requirements.

David Berry 4 years ago / Reply

ATPL sine 1974 and now just leisure flyingIs anyone able to point me at the self declaration form which is required to be submitted in place of the previous version requiring one's GP signature?Many thanks and clearly a lot of hard work has gone into achieving this very practical approach to a knotty subject....Job well done.David

Ed Bellamy 4 years ago

Hi David, thank you for your comments. The form is now available from our page on medical requirements.

Donald Smith 4 years ago / Reply

The 2016 ANO states(3) The holder of a licence makes a medical declaration in accordance with this article if they(a) reasonably believe that they(b) make a declaration to that effect to the CAA in such form and in such manner as may berequired or specified by the CAA; andWhat Form is required for this declaration. The current list makes no provision for this procedure. Is the current GP form still valid it can be down loaded?

Ed Bellamy 4 years ago

No, the old form is not valid, you must use the new one specified by the CAA.

Donald Smith 4 years ago / Reply

If a pilot has an older JAR licence, can this licence still be used with a Medical Declaration with NPPL privileges? My understanding is that this was previously possible under the old ANO, or amendment thereof.

Ed Bellamy 4 years ago

A JAR licence is effectively deemed to be an EASA Part-FCL licence. It may be used with a medical declaration on EASA aircraft until April 2018 (within the privileges of an NPPL) and is valid on non-EASA aircraft within the limitations of the medical declaration itself – i.e. no more than 3 people on board and aircraft up to 5700kgs MTOM.

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