Italian charter permits and associated requirements have changed a few times in recent years. Today, permit requirements vary depending upon where your aircraft is registered, passenger seating capacity, where it is operating, and how recently you’ve conducted a charter operation to Italy. Generally, the Ente Nazionale per ‘l’Aviazione Civile (ENAC), the Italian Civil Aviation Authority, is stringent regarding regulations and the documentation that must be submitted.

Italian charter landing permit requirements

All charter (non-scheduled commercial) flights by non-European Union-registered aircraft require landing permits. For aircraft with up to 19 passenger seats, these operations are called “air taxi flights.”  A charter blanket permit covers an ‘operator’s entire fleet, assuming all aircraft have been specified on the EASA TCO and it’s issued permanently. The permit is only granted validity through the insurance terms and all the other relevant documents validity. For example, if the insurance is only valid for an additional six months on the date of application, then the permit will only be valid for six months. A one-shot permit is available for single flights and is faster to obtain, but it doesn’t cover the entire operator’s fleet.

Air taxi Definition

An air taxi flight involves transporting passengers, with their freight (baggage), under a single charter contract for the entire capacity of an aircraft with no more than 19 passenger seats.

Exemptions for EU-registered aircraft

EU-registered charter aircraft with 19 passenger seats or less do not require landing permits. While such operators should submit a ground handling request and file a flight plan, ENAC does not require a special permit or notification.

Processing landing permits

Processing time for a charter permit is up to 40 days, and it’s valid if the operator lands within the EU in the two IATA seasons. IATA seasons are March-October and October-March. Otherwise, the permit processing time is 45 business days. Accreditation to ENAC is up to 45 business days before the flight operation and 40 working days for a blanket permit. In the case of a single flight permit, the leading time is shorter, up to 5 days (one shot permit). In the case of a series of flights, the request must be made up to 15 days before the flight.

Permit processing hours

ENAC processes charter permits Monday-Friday, 0900-1700 local. The office is closed on weekends and holidays. No after-hours permit processing is possible under any circumstances, and after-hours contact numbers are unavailable.

Requirements for non-EU-registered aircraft

Operators applying for a first-time charter to Italy – or those who have not operated to Italy during the past two IATA seasons – must submit specific documentation to the Italian Air Transport Development Division and apply for EASA TCO and ENAC accreditation.

Domestic operations

Your charter landing permit specifies which Airports of Entry (AOEs) you may travel to within Italy. To travel to a domestic airport, you must first arrive/depart via an Italian AOE. Note that, for domestic travel within Italy, you may not carry passengers who are not associated with your international legs, which would be considered cabotage. In other words, you may not board any additional passengers that you did not bring into Italy. At some point in the future, it’s anticipated that Italy may expand its cabotage restrictions – to include travel to and within other EU countries – but this has not yet occurred, and no date for implementation has been announced.

TCO requirements

Ente Nazionale per ‘l’Aviazione Civile (ENAC), the Italian Civil Aviation Authority, began requiring the Third Country Operator (TCO) authorization as part of the landing permit requirements in 2013. As of November 26, 2014, TCO authorizations must be valid at the time of the Italian landing permit requests. Your landing permit will not be processed if the TCO authorization is invalid.

Required information

When you request a charter landing permit, the following information/documentation is required:

• Air Operator’s Certificate (AOC)
• Operation specification D085 (aircraft listing)
• A003 aircraft authorization
• A999 certification statements
• Operator’s full address and information
• The insurance certificate for Italy (ENAC’s format) must include all owned and leased aircraft being submitted for the permit. ENAC’s specific verbiage and format need to be followed. You cannot use a generic EU insurance format, which will be rejected.
• A letter from the civil authority in the country where the aircraft is registered stating that the operator’s security program has complied with International Civil Aviation Organization Annex 17 is usually found within the operator’s security program.
• A foreign ‘operator’s questionnaire (FOQ) is only needed if the landing permit application is for aircraft with more than 19 seats.
• Letter to authorize your trip support provider (Universal Aviation Italy) to be able to process the permit on your behalf, as the 3rd-party provider will be representing the operator with applying ENAC. This letter needs to be on the company letterhead, signed and notarized. (This is the power of attorney.)
• TCO certificate – or proof that the application has been made (ENAC will double-check with the European Aviation Safety Agency that this has been done).

Additional notes: The insurance needs to be in the unique format ENAC provides. Once the insurance expires, it is necessary to submit another valid one to keep the blanket permit, which is to submit the new insurance before the one submitted expires. If this ‘isn’t done, ENAC will not consider the permit valid, and if the operator travels to Italy after the original insurance was submitted, ENAC may fine the operator.

Air Carriers – charter aircraft with more than 19 passenger seats

If your charter aircraft is not EU-registered and has more than 19 passenger seats, you’re considered an “air carrier.” The flight classification is considered a charter, and you must submit a different type of landing permit request, specifically for air carriers. This particular type of Italian landing permit is available as a one-shot or annual permit, which requires submission to ENAC with all relevant documentation and a FOQ. Carriers applying to operate a first-time charter to Italy (or who have not operated a charter to Italy during the past two International Air Transport Association seasons) must submit their application to the Air Transport Development Division and include the following:

• An FOQ validated by the ‘applicant’s aeronautical authorities—except for carriers registered in the U.S., Canada, and Turkey.
• AOC with complete operational specifications
• Certificates of registration, airworthiness, and noise, as well as ACAS II EGPWS certification
• Insurance certificate issued according to EU Regulation 785/2004 and in compliance with ENAC standards (unique format issued by ENAC)
• A completed security program

Processing time for an Italian air carrier landing permit

The processing time to approve an air carrier landing permit is 45 business days. When making a permit application, the operator may include all aircraft with more than 19 passenger seats in the fleet. Any aircraft with 19 or fewer passenger seats must be processed separately under the charter classification. Note that EU-registered charter aircraft under the air carrier classification do not require permits but must submit a notification to ENAC with a minimum 24-hour lead time, and this notification must include an applicable flight schedule.

Permit revisions – for all charter permit types

Once a charter permit is approved, it can be revised if another aircraft needs to be added to the listed fleet. To do this, documentation for the additional aircraft is forwarded to ENAC.

All-inclusive tour and special event charters

All applicants for inclusive tours and special event charter flights must also submit:

• A copy of the charter contract signed by the “airline” and the ” tour operator. “
• Website address of the tour operator who advertised and sold the applicable flights in question.
• A ‘shipper’s declaration listing the origin and/or destination of all goods on board the aircraft.

Application for traffic rights (landing permits) concerning all-inclusive tours and ad-hoc flights must be submitted five days before a single flight and 15 days in advance in the event of a series of flights. Note that a special event charter flight is considered one where the aircraft is chartered for passengers attending a sport, cultural, or professional event. etc. For such flights, the origin and return destination (after traveling to Italy) must be the same, and it must be operated with aircraft with more than 19 passenger seats.

Expedited permits

Expedited landing permits usually are only possible for diplomatic and/or air ambulance/emergency flights. In most cases, diplomatic flights – even though they may be charters – are exempted from Italian charter landing permit requirements, so long as ‘they’re classified correctly and go through appropriate diplomatic channels for flight approval. ‘It’s recommended that your 3rd-party provider confirm this information for your flight.

Conclusion

If regulations are not followed or proper documentation is not submitted, ENAC will not process your charter landing permit. For permit renewals, ‘you’ll only need to submit documents that may have expired or will expire shortly (within the next year). Documentation that remains valid must not be re-submitted with your charter permit renewal.

The lead times for Italian charter permits are firm, and short notice permit requests are generally impossible. Once a charter permit application has been made and all required documentation has been submitted, the operator may travel to Italy without notice once the permit is approved.

All TCO authorizations must be submitted with all Italian landing permit requests. Otherwise, your landing permit will not be processed. Note that landing permit requirements change for aircraft over 19 seats, as well as for inclusive tours and special event charter flights.

Always pay close attention to Italian cabotage restrictions and regulations. If you have questions on Italian cabotage restrictions, then ‘it’s recommended that you speak with your 3rd-party provider.