Singapore’s Civil Aviation Authority (CAAS) is introducing new regulatory requirements under ANR-129 – Foreign Operator’s Permit (FOP) Regulations, set to take effect in mid-2025. These regulations will replace the current Air Navigation Order (ANO) and establish a clearer framework for foreign commercial air transport (CAT) and aerial work (AW) operations in and out of Singapore.

For business aviation operators, compliance with ANR-129 is essential to avoid operational disruptions. The regulation introduces new permit requirements, notification obligations, and financial penalties for non-compliance.

Who Needs a Foreign Operator’s Permit (FOP) Under ANR-129?

Under ANR-129, foreign Air Operator Certificate (AOC) holders conducting commercial air transport (CAT) operations into Singapore will require a Foreign Operator’s Permit (FOP). However, the requirement depends on how the operation is set up:

• If an operator does not hold an AOC, an FOP is not required.
• If an operator holds an AOC but the aircraft is not listed under it, an FOP is also not required.
• If the aircraft is listed under an AOC, an FOP is required even for non-revenue flights.

This means that foreign AOC holders operating under ANR-129 will need an FOP for:

• Charter flights – Both revenue and non-revenue operations.
• Passenger and cargo operations – Including medevac flights.
• Technical stops and positioning flights – Even if no passengers or cargo are offloaded.
• Aerial Work (AW) operators – If the aircraft:
  • Takes off or lands in Singapore.
  • Conducts aerial work over Singaporean airspace (e.g., aerial surveys, photography).

Does a Part 91 Operator Need to Comply?

No, if the operator does not hold an AOC.

Private Part 91 operators flying non-commercial missions without an AOC do not require an FOP. However, if an operator holds an AOC, they must comply with ANR-129, even for non-revenue flights such as ferry, positioning, or maintenance operations.

Who is Exempt from the Permit Requirement?

The following operations do not require an FOP:

• Emergency landings
• Diplomatic flights (subject to Ministry of Foreign Affairs approval)
• Alternate aerodrome landings
• Maintenance flights (with no passengers or cargo)
• Overflights

New Compliance Requirements for Operators

FOP Holder Responsibilities

Operators holding an FOP must comply with ongoing reporting obligations, including:

• Notifying CAAS of any changes to:
  • Company name
  • Principal place of business
  • Operational specifications (e.g., switching from passenger to cargo operations)
  • Appointed representative responsible for safety matters
• Providing a local Singapore-based address for official correspondence.

Representative Requirement

All FOP holders must appoint a designated representative to liaise with CAAS on regulatory matters. This individual:

• Must hold a senior management role (e.g., Director of Flight Operations, Safety, or Quality).
• Does not need to be based in Singapore but must be registered with CAAS.
• Operators must notify CAAS within five business days if this representative changes.

Financial Penalties for Non-Compliance

CAAS is introducing financial penalties for violations under ANR-129:

Timeline for ANR-129 Implementation

• February–March 2025 – Industry consultation and stakeholder feedback.
• April 2025 – Expected publication of final ANR-129 regulations.
• Mid-2025 – ANR-129 goes into effect – All foreign AOC holders must comply.

Note: Existing Operations Permits (OPs) issued under the ANO will remain valid until their next renewal.

Key Takeaways for Business Aviation Operators

• Foreign AOC holders conducting charter or cargo flights (even non-revenue) must apply for an FOP.
• Exemptions apply to diplomatic, emergency, maintenance, and overflight operations.
• Private (Part 91) operators without an AOC do not require an FOP.
• Operators must designate a representative and provide a local address for regulatory communications.
• Financial penalties apply for non-compliance.
• Existing permits remain valid until their renewal, but operators should prepare for the transition.

Next Steps

• If your operation holds an AOC and your aircraft is listed under it, ensure you apply for an FOP before mid-2025 to avoid disruptions.
• If you are a private (Part 91) operator without an AOC, you do not need to take any action.
• For charter operators, consult your handling provider or regulatory advisor to ensure compliance.

Staying ahead of regulatory changes is key to avoiding costly delays and penalties. If you need assistance, contact Universal Aviation Singapore for the latest updates and guidance.