fees and charges memorandum fees... · despite only modest increases in line with inflation, and...
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EUROPEAN UNION AVIATION SAFETY AGENCY
FEES & CHARGES REVIEW
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FEES AND CHARGES MEMORANDUM
The European Union Aviation Safety Agency (EASA) is in the process of reviewing the fees and charges (F&Cs) it levies on its applicants for the issue of certificates and approvals.
The proposed amendments are important in order to:
— modernise the F&Cs system in line with the latest innovations and emerging technologies, and with EASA’s extended scope of activities according to Regulation 2018/1139;
— ensure that EASA continues to have the necessary resources to fulfil its mission and meet the growing needs of applicants and the travelling public for high-quality certification and approval services in the context of an increasingly competitive aviation industry; and
— constantly improve the application of the F&Cs system to reduce its administrative burden on both EASA and its applicants.
This memorandum details the proposed amendments and their objectives following a brief description of the context in which this F&Cs review is conducted. The F&C review is an ongoing process and the proposal might still be modified in the next months. The main parts modified since the original memorandum was distributed in June 2018 are highlighted.
The memorandum is structured as follows:
INTRODUCTION
A. CONTEXT OF THE F&Cs REVIEW
B. NEED FOR AND OBJECTIVES OF THE F&Cs REVIEW
C. PROPOSED AMENDMENTS TO THE F&Cs SYSTEM
D. NEXT STEPS
APPENDIX A: PROPOSED PRICE TABLES
APPENDIX B: MAIN OPTIONS CONSIDERED BUT NOT RETAINED
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INTRODUCTION
The aviation industry is changing rapidly. More people are flying to more destinations. Organisational
business models are being transformed to accommodate drones, digitalisation, robots, connectivity
and additive manufacturing. New entrants to the market are designing, manufacturing and operating
products. The pace of innovation is increasing.
As an aviation safety regulator, EASA must keep pace with these developments and continue to ensure
the level of safety and added value for which it is recognised worldwide.
A hallmark of quality worldwide
Internationally accepted standards are a major contributor to growth, particularly for innovative
technologies. EASA standards are recognised globally and, as an international benchmark, are
increasingly being adopted by other regulators as an alternative to developing national standards.
EASA invests heavily in the gradual convergence of international aviation safety regulations towards a
level that is equivalent to its own. Establishing mutual trust among national regulators is a continuous
task that requires leadership, effort, and technical knowledge.
Industry benefits directly from this harmonisation because it facilitates market access worldwide,
reduces time to market, increases overall safety levels, and lowers costs. Indeed, the quicker new
certified products and services can be brought to the market, the safer and more efficient the market
will be. Achieving EASA certification is a de facto demonstration of meeting appropriate safety
standards for any national regulator worldwide.
A responsive, long-term partner
EASA is to a large part financed by fees charged to applicants that benefit from its services.
EASA is therefore keenly aware that its services have to be of high quality to justify the cost. Thanks
to its quality management system that complies with the ISO 9001 standard, EASA is able to
demonstrate continuous improvements. This is essential in view of the increasing aircraft fleets that
are flying under the EASA oversight, leading to higher exposure and more accountability.
EASA is valued as a stable, long-term partner and due to its comparatively small size compared to
other regulators, is regarded as a dynamic, innovative organisation. A recent example is the
introduction of risk- and performance-based oversight that will optimise over time the compliance
efforts made by industry. EASA’s management is committed to manage lead times and increase the
transparency of the certification process. By investing in digital transformation programmes, EASA
intends to establish the world’s most connected and efficient certification process for aviation.
The need to amend the fees system
EASA has not adjusted its fees materially since 2014. In addition, as from 2016, EASA supports
additional staff costs linked to pension contributions. After a thorough review, EASA has come to the
conclusion that the revenues from some of its services no longer cover the associated costs and it
therefore needs to adjust its pricing. The proposal set out below aims to bridge this gap in revenues
as of 2020, taking into account forecast developments over the next 5 years.
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Additional benefits for industry
At the same time, EASA has taken steps to improve the way it charges by reviewing every service and
fee category. Applicants will see that:
— in addition to existing privileges for minor changes/minor repairs, design organisation approval
(DOA) holders may now also be granted privileges, under conditions, to carry out some major
change work and Maintenance Review Board items;
— DOA holders with an existing alternative design organisation approval for European technical
standard orders (ETSOs) can lighten their management burden by incorporating the privilege
under their DOA and benefit from a reduction in EASA’s level of involvement (LoI) in some
individual projects;
— fees proposed for product design certificates now cover Operational Suitability Data (OSD) and
Management Review Board (MRB) activities;
— significant leaps in fees among adjacent categories have been smoothed out; and
— a new range of partnership services will be offered in order to support research as well as
development activities and innovation.
EASA has overhauled the annual price adjustment mechanism. A regular price review mechanism will
allow to gradually adjust prices in a transparent and structured way, reflecting not only cost evolution
(including necessary investments) but also efficiency gains, for which specific targets will be defined
and to which EASA will commit. This structural mechanism will be embedded in the 3-years Single
Programming Document, approved by EASA’s Management Board and monitored through the same
governance system.
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A. CONTEXT OF THE F&Cs REVIEW
Financing EASA
To fulfil its tasks, EASA mobilises resources that are financed by several sources (including a contribution from the Union and participating States) and fees paid by applicants for, and holders of, certificates and approvals issued by EASA, and charges for publication, training and other services.
The current review focuses on fees and charges (F&Cs).
The Fees & Charges Regulation
Commission Regulation (EU) No 319/20141 (the F&Cs Regulation) determines the cases where F&Cs are due, their amount, and how they are to be paid. The fees levied by EASA for most of its certification and approval activities are ‘yearly fixed fees’ calculated on an annual basis.
Fees for most product certification activities are determined by the nature of the activity (e.g. major change approvals or continuing airworthiness activities) and other factors that are specific to each activity (e.g. maximum take-off weight (MTOW), or complexity). Fees for most organisation approval activities are determined by the type of organisation approved (e.g. design or production organisation) and other factors specific to each organisation type (e.g. turnover, number of staff, or type rating).
While the F&Cs Regulation provides a fixed fee for most certification and approval activities, other activities are charged at an hourly rate.
The F&Cs Regulation provides a mechanism by which all fees and charges are automatically adjusted annually in line with the change in the Harmonised Index of Consumer Prices (HICP). HICP inflation has been relatively low in the last few years. Since the adoption in 2014 of the current F&Cs Regulation, HICP inflation led to a total cumulative increase of only 2.3 % over the last 4 years, the equivalent of a mere 0.6 % increase per year.
B. NEED FOR AND OBJECTIVES OF THE F&Cs REVIEW
The adoption of the current F&Cs Regulation in 2014 led to substantial improvements. It introduced a simple, predictable and widely accepted approach based on annual flat fees for the majority of certification activities. Until recently, the revenues generated supported EASA’s need to grow and strengthen its position as a global leader.
While the foundations of the current F&Cs Regulation remain appropriate today, the need to modernise some important aspects emerged recently. This comes as no surprise knowing that between 2005 and 2008 the F&Cs Regulation in force at the time was the object of regular minor amendments, while the current F&Cs Regulation has not been amended since 2014, and once it is adopted, the revised F&C Regulation is expected to enter into force in 2020. However, for various reasons detailed in the following sections, more frequent adjustments of the F&C are required to ensure the Agency’s budget is sustainable over time. Indeed, the costs and revenue projections informing the revision in 2014 turned out to be more pessimistic than actual results, leading to initial surplus being accumulated. This surplus, combined with cost control, allowed to sustain the Agency despite only modest increases in line with inflation, and postpone the revision until 2020. With the
1 Commission Regulation (EU) No 319/2014 of 27 March 2014 on the fees and charges levied by the European Aviation Safety Agency,
and repealing Regulation (EC) No 593/2007 (OJ L 93, 28.3.2014, p. 58).
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next revision of the regulation EASA intends to achieve a more transparent and measured system that allows smaller, more regular adjustments that track actual conditions more closely.
The main objectives of the F&Cs review mirror the three main causes for the emerging need to modernise the current F&Cs Regulation:
1. Adapt to new technologies and additional responsibilities for EASA;
2. Create a sustainable system allowing long-term financial stability, to balance financial deficit and a forecast of deficit growth, due largely to preserving expertise and covering staff pension contributions previously financed from EU subsidy;
3. Further streamline the application of the F&Cs system.
New technologies and new responsibilities for EASA
The current F&Cs Regulation provides a fee structure based on specific product categories (such as ‘fixed-wing aircraft’, ‘rotorcraft’, ‘airships’ and ‘balloons’) and organisation categories (such as ‘design organisations’ and ‘maintenance organisations’). Those categories are fixed and are intended to be mutually exclusive and collectively exhaustive. Accordingly, the certification fees for any aircraft that cannot be categorised as either ‘fixed-wing aircraft’, ‘rotorcraft’, ‘airship’ or ‘balloon’ will automatically be calculated using an hourly rate. The same holds true for other product categories and organisations.
However, the aviation industry continues to introduce innovative products and technologies that challenge traditional categories. For example:
— Remotely Piloted Aircraft Systems (RPASs), commonly known as ‘drones’;
— hybrid fixed-wing/rotor aircraft that are designed to take off vertically using tilting rotors and change configuration in flight to create lift using fixed-wings during cruise;
— electrical engines that form integral part of an aircraft framework.
In parallel, Regulation 2018/1139 has extended the scope of organisations EASA can approve. However, the current F&Cs Regulation does not provide for an appropriate fee structure for these new organisations. Fees will thus be calculated on an hourly rate — an approach that applicants describe as unpredictable and that generates considerable administrative burden for both EASA and its applicants compared to a flat fee.
EASA thus needs a more flexible method of charging for novel products and organisations. To ensure cost-reflectivity, this new flexible proposal embraces the risk-based approach being adopted by EASA at technical level.
Financial deficit and forecast of deficit growth
In 2016, for the first time since the F&Cs Regulation was introduced in 2014, the F&Cs levied by EASA were insufficient to cover the costs of its certification activities. According to EASA’s forecasts, this deficit will continue to grow in the future. This is due to several factors:
1. Expertise in new technologies. The challenge for EASA goes beyond a simple revision of its fees structure. EASA must also create the conditions to invest in building its internal knowledge and constantly look to attract the world’s best talent to ensure it remains at the forefront of innovation and provides its applicants with the best services possible. Fees mostly cover the cost of EASA’s staff that work on certification activities. These include aeronautical engineers and other aviation experts whose primary goal is to ensure safety of the public. Innovation
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drives increased costs for all activities of EASA, and fees have proven to be insufficient to cover those growing costs.
2. Changing business models. EASA has typically worked on several type certificates per year in the past, the fees accounting for a material part of the total fees levied. The volume of type certification activities, however, has decreased recently. This is a consequence of the decision by some large aircraft manufacturers not to launch new programmes and to instead focus on developing derivatives and major changes for their existing platforms.
In turn, the complexity of the derivatives and major changes has risen, increasing the cost of any single certification activity. Despite this increase in costs, the level of fees levied per certification activity has remained unchanged (save for inflation adjustments). As a result, the fees levied for the certification of a derivate or major change have become insufficient to cover the costs of certification. The issue is exacerbated by the increase in the volume of derivatives and major changes that EASA certifies.
3. Higher expectations from the public and applicants. Public expectations for safe, reliable, comfortable and environmentally friendly air transportation solutions are increasing globally. Applicants are expected to include the very best of technology in their products and services, and to do so quicker than ever before. At the same time, the emergence of new aviation players from developing countries changes the dynamics of the industry following decades of consolidation, leading to increased competition globally.
In turn, expectations from applicants towards EASA are also increasing: applicants demand quicker, more efficient, more transparent and more predictable certification services from all their regulators. As EASA mobilises resources in an effort to better meet those needs, the costs of its services increase and surpass the fees levied for them.
4. Inadequate yearly adjustment mechanism. Staff costs, which account for the majority of EASA costs, and fees are not adjusted in line with the same index. As a result, costs have grown more quickly than revenues since 2014.
5. Outsourcing strategy. To match the growing workload, deal with the cap set by the EU budgetary authority on the number of experts EASA is allowed to hire as well as to optimise the use and sustainability of the EU national aviation authorities’ (NAAs) technical capacities, EASA relies on NAAs to perform traditional certifications analysis. The cost of outsourcing to the NAAs is borne by EASA and represents a significant portion of its total costs. Again, costs have risen at a rate that is significantly greater than HICP inflation. Since fees have only increased in line with HICP inflation, the situation has further contributed to costs growing more quickly than revenues.
6. New approach to certification and approval. EASA is constantly looking to improve its ways of working. For example, EASA is strengthening its processes on determining its level of involvement (LoI) in certification projects. Based on this, EASA will systematically determine its LoI in a risk-based manner. With that, it will focus on high-risk elements during a certification project. In line with this new risk-based approach during initial certification, EASA also adopted a plan to ensure appropriate oversight during continuing airworthiness. This includes how resources are allocated among activities and what costs are incurred at different phases of the life cycle of a product or an organisation. This in turn requires a rebalancing of fees among activities.
At the same time, EASA regularly reviews its internal procedures and ways of working at all levels of the organisation to ensure it continues to make the very best use of its resources. The goal is to limit the need to mobilise additional resources in the future despite the growing volume of highly specialised work generated by emerging technologies. Improved efficiencies, however, will by
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themselves be insufficient to address the forecast growing deficit, and amendments to the F&Cs are thus inevitable to address the deficit.
Opportunities to further streamline the application of the F&Cs system
EASA has identified other opportunities to further improve the F&Cs Regulation. These opportunities are aimed at simplifying the application of the F&Cs system for both EASA and its applicants, leading to savings on both sides.
C. PROPOSED AMENDMENTS TO THE F&Cs SYSTEM
Taking into account the feedback received from its applicants, EASA has identified three categories of amendments to the F&Cs Regulation it wishes to propose:
1. Adapt fees to new technologies and to the future extended scope of responsibilities of EASA.
EASA proposes to:
— adopt flat fees for the certification of new products that are currently not covered by flat fees in the current F&Cs Regulation;
— redefine existing fee categories of ‘fixed-wing aircraft’ and ‘rotorcraft’ to clarify how new hybrid aircraft models should be classified;
— introduce a flexible risk-based pricing mechanism to set fees for the certification of novel products and organisations that are currently not covered by an existing fixed fee structure in the F&Cs Regulation but that are still too nascent for EASA to propose a flat fee at this point.
2. Adjust F&Cs to ensure present and future cost-reflectivity.
EASA proposes to:
— adjust the fees for loss-making services so they cover their full costs. This includes introducing charges for third-country operators (TCOs) for additional activities required for some third-country operators;
— replace the current automatic price adjustment mechanism based on HICP inflation by one that captures the true cost increases EASA is subjected to through a transparent governance model embedded in the Single Programming Document and approved by the Management Board, including a commitment by EASA to achieve efficiency gains.
3. Introduce amendments to improve the overall efficiency and application of the system.
EASA proposes other amendments aimed at improving its overall efficiency, such as:
— streamlining and defining different categories of “major changes” replacing “derivatives” to ensure clarity among the applicants;
— changing the metric used as a basis for setting fees for the approval of production organisations from turnover to number of staff and price of most expensive products, given the challenge applicants and EASA face under the current system to determine the appropriate scope of activities to be considered in calculating turnover;
— simplifying the MTOW fee tier structure for the certification of small fixed-wing aircraft, and adapting it to new market realities;
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— modifying the flat fees to include Operational Suitability Data (OSD) and Maintenance Review Board (MRB) activities, currently charged separately through hourly rate, to simplify the process for both the applicants and EASA;
— creating a flat fee for Flight Simulation Training Devices (FSTD) activities; and
— creating a flat fee for MRB activities.
The proposed amendments are further detailed in the following tables.
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PROPOSED AMENDMENTS CATEGORY #1: Adapt F&Cs to new technologies and to the future extended scope of responsibilities of EASA
# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
1 Introduce a new fee structure for the issue of type certificates and the continued airworthiness of remotely piloted aircraft systems (RPASs) – fees proposal not yet presented in this memorandum.
— The current F&Cs Regulation does not provide a flat fee for the certification of RPASs.
— The existing ‘fixed-wing aircraft’ and ‘rotorcraft’ categories are not fit for purpose for RPASs, which are fundamentally different machines.
— The absence of flat fees in a dedicated product category table in the F&Cs Regulation leads to uncertainty on the fees to be levied for the issue of certificates for RPASs, ultimately negatively impacting on innovation in this field.
— Introduce new fees for the issue of certificates and continued airworthiness of RPASs.
— Structure the fees to follow the RPAS classification in the EASA Opinion 01/2018, following stakeholders feedback that the originally proposed fees based on use cases might not be the most appropriate structure.
— Set fees such that they are cost-reflective
— Increased certainty and predictability of fees payable by applicants for the certification of RPASs thanks to a tailored fee structure aligned with the coming regulation.
— Improved cost-reflectivity of fees.
— TBD as soon as the proposal is more mature.
2 Redefine ‘fixed-wing aircraft’ and ‘rotorcraft’ fee category definition
The traditional distinction between ‘fixed-wing aircraft’ and ‘rotorcraft’ is challenged by hybrid aircraft that are designed to take off vertically using tilting rotors and change configuration in flight to create lift using fixed-wings during cruise.
— Amend the definition of the ‘fixed-wing’ category for ‘horizontal take-off and landing (HTOL) aircraft.
— Amend the definition of the ‘rotorcraft’ category for ‘aircraft with vertical take-off and landing (VTOL) capabilities’.
— Improved clarity on which category hybrid aircraft fit in (i.e. VTOL, if the aircraft has vertical take-off and landing capabilities).
— Improved cost-reflectivity, given the aircraft complexity (and expected certification workload) of a hybrid aircraft is closer to that of a rotorcraft than of a fixed-wing aircraft.
No financial impact anticipated for applicants and EASA inasmuch as hybrid aircraft are classified as ‘rotorcraft’ under the current F&Cs Regulation.
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# Proposed amendment
Targeted issues Description of the proposed amendment Intended benefits Assessment of impact
3 Adopt a flexible risk-based fee-setting mechanism for novel products and organisations
— The current F&Cs structure is not fit for purpose for novel products that integrate technologies new to EASA.
— The current F&Cs structure is not fit for purpose for novel organisation types not currently approved by EASA and for which no fees are set, but possibly included in the scope of activities of EASA under the Regulation 2018/1139.
— In these cases, the current F&Cs Regulation provides the ability for EASA to charge such activities using an hourly rate, but doing so is uncertain for applicant and could lead to inappropriate results; indeed, the first applicant to apply for the certification of a novel product or the approval of a novel organisation type would bear all the costs of EASA knowledge-building needed to complete the activity for the first time, to the unfair benefit of the following applicants whose costs for certification or approval would be much lower given the ability for EASA to leverage the knowledge on the novel product or novel organisation type it has already developed.
— The above, leads to uncertainty for applicants and impedes innovation.
— Introduce a flexible risk-based approach to setting certification fees for novel products and organisations.
— Novel products will be those of such innovative nature that it falls outside existing certification specifications and corresponding applicable means of compliance. Novel organisations will be those whose type is not the object of an existing fee table.
— Applicants seeking the certification of a novel product or the approval of a novel organisation will be required to initiate a Technical Advisory Contract (TAC) or a similar contract with EASA, to clarify the technical details of the project in order to assess the workload and the fee. The analysis which will be conducted in order to assess the risk and workload will be charged on hourly basis and will reduce the workload required in the actual certification/approval phase.
— During the assessment phase, EASA will determine a fixed price for the activity in the form of a financial quote based on an estimate of the risk level of the product/organisation.
— Increased certainty and predictability of fees thanks to the fixed-fee approach.
— Improved cost-reflectivity and fee accuracy given the detailed assessment through a technical advisory contract (TAC) or similar contract, and the alignment with EASA’s new risk-based approach to certification/approvals in estimating the risk and workload needed for the service.
— Increased support to innovation.
— EASA expects the majority of products certified and organisations approved to be considered ‘traditional’ and not affected by this proposal.
— Applicants whose product or organisation is considered novel could see in certain circumstances a decrease or increase in their fees compared to the most similar product or organisation for which a flat fee exists, depending on the degree of novelty.
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PROPOSED AMENDMENTS CATEGORY #2: Ensure present and future cost-reflectivity of F&Cs
# Proposed amendment
Targeted issues Description of the proposed amendment Intended benefits Assessment of impact
4 Adjust the fee for loss-making services
— The F&Cs levied by EASA are insufficient to cover the costs of its certification and approval activities, resulting in a deficit.
— For many activities, costs have grown quicker than (and now exceed) fees, resulting in activities that are now loss-making. By 2020, all groups of activities are forecasted to be loss-making.
— While EASA is taking all necessary actions to ensure it remains financially strong and able to fulfil its mission as a regulator, improved efficiencies will by themselves be insufficient to address the forecasted growing deficit and amendments to the F&Cs to address the deficit are thus inevitable.
Increase the fees for the following activities to ensure all services cover their full costs (see Appendix A for resulting new prices):
Supplemental Type Certificates (STCs);
Major changes (incl. derivatives – now replaced by “complex significant change”);
Minor changes;
TC continued airworthiness and removal of rebate for holders of TCs in identical categories – the fee increase in this area has been limited, to partially compensate for the impact of the rebate removal;
Design Organisation Approval (initial);
Design Organisation Approval (continuous);
Product Organisation Approval (initial and continuous): various adjustments through changes in fee structure (see proposal #8 below);
Maintenance Organisation Approval (initial);
Maintenance Organisation Approval (continuous);
European Technical Standard Orders Approval (initial);
European Technical Standard Orders Approval (continuous).
— Ability for EASA to mobilise the necessary resources to fulfil its mission as a regulator.
— Improved cost-reflectivity of fees.
— High quality of services kept and continuous improvement offered by EASA to its applicants.
— Some applicants are expected to see an increase in the fees they pay for their requests for certification and approval services.
— EASA estimates that the direct impact on the amount of fees paid by applicants generally could range between approximately 0 and 35 % depending on the mix of services they receive from EASA.
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# Proposed amendment
Targeted issues Description of the proposed amendment Intended benefits Assessment of impact
5 Introduce a fee for additional activities required for some third-country operators (TCOs)
— The authorisation and continuous monitoring of TCOs is currently provided free of charge to the operators.
— The situation is not consistent with the general principles ruling the financial scheme of the Agency. In particular, some TCOs require significant additional technical investigation but are not requested to pay any fees for the extra activities required.
— The Agency initially proposed to levy a flat fee for the authorisation and continuous monitoring of TCOs based on the total fleet size (<10, 10–50 or >50) and the category of aircraft the TCO flies (‘large’ if at least one aircraft in the airline fleet has an MTOW greater than 45.5 tonnes, or if at least one aircraft can carry at least 20 passengers).
— Based on stakeholder feedback, alternative options were considered. The current proposal is performance-based charging, and would limit charging only to technical meetings in Cologne and on-site visits.
— Allows partial self-financing of the activity.
— Only the TCOs which require deeper assessment according to Part-TCO will be required to pay.
— Only a very limited number of TCOs would be impacted: the ones needing an on-site visit or a technical meeting in Cologne.
— In the past some fear has been expressed on the risk of retaliation by other countries. EASA believes the currently considered option minimises this risk.
6 Introduce a yearly fee adjustment mechanism that accounts for the expected evolution of EASA costs, including efficiency gains
The current F&Cs Regulation provides that fees and charges increase automatically every year in line with HICP inflation, a metric that leads to increases that are systematically below the growth rate of the EASA costs (especially staff and outsourcing costs).
— The yearly fee adjustment mechanism will be replaced by one that captures all relevant EASA costs, allowing EASA to agree on a 3-year budget of costs and investments with its Management Board (MB), including the European Commission, EASA Member States and aviation industry and to then adjust its fees yearly in line with these costs, including a commitment to achieve predetermined efficiency gains.
— The price review mechanism will have an underlying performance plan fully embedded in the Single Programming Document (SPD), with the same governance mechanism, i.e. PAR and MB.
— The performance plan will be established by EASA for a 3-year “reference period”. It will be reviewed every 3 years, not annually like the SPD.
— EASA will establish a clear mechanism to monitor the elements that define the % of price adjustment, including efficiency.
— Price adjustments will apply as a % change to all flat fees (and hourly rate) included in the F&C regulation. The financial situation per group of activities will be continuously monitored and the specific prices will be reviewed through Comitology when needed.
— Ensures EASA remains financially solid in the future and has the necessary resources to fulfil its mission as a regulator.
— Removes the need for periodic large fee adjustments at every revision of the F&Cs Regulation to make up for the otherwise growing gap between revenues and costs.
— Ensures EASA commits to efficiency gains, embedded in the performance plan.
The fee adjustment mechanism will properly capture all cost increases EASA needs to bear and factor in efficiency gain targets EASA will commit to. This will contribute to cost-reflectivity.
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PROPOSED AMENDMENTS CATEGORY #3: Introduce various other amendments to improve the overall efficiency and application of the F&Cs system
# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
7 Define the scope of what constitutes a ‘major change’ versus a ‘complex significant change’ (replacing the “derivative” concept)
— In the current F&C regulation, the categories ‘derivative’ and ‘major changes’ are not defined, creating confusion among applicants.
— As a result, applicants tend to apply for ‘major changes’ for which the fee is lower, even though in some instances the more appropriate category would be ‘derivative’.
— Change the category of ‘derivatives’ to ‘complex significant change’.
— Change the category of ‘complex major change’ to ‘significant major change’.
— Define how these categories differ – see Appendix C.
— Introduce a model fee in order to reflect a new model in the TC.
— Improve clarity for applicants on what constitutes each category.
— Align the categories to the technical work performed.
— The introduction of a model fee adds the option to apply for a new type of change that might be interesting for industry.
EASA expects that a few applications for major changes will be reclassified as complex significant change and vice versa, although the exact number is expected to be small.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
8 Change the metric used as basis for pricing the approval and surveillance of production organisations from turnover to the number of staff and the price of most expensive products
Although conceptually sound, the use of turnover as basis to determine the fees for product organisations proves problematic in its application. Indeed, for organisations that have more than only a production function (which is often the case), EASA must determine the exact part of the organisation that is attributable to production to calculate turnover properly. This can lead to uncertainties and the need for both EASA and the applicant to dedicate resources to clarify how the turnover should be calculated in any given year.
Introduce a new fee table that is based on number of staff and highest priced product.
— The number-of-staff metric is objective and easier to apply given it is included in the POA documents of the applicant; it is also already successfully used in determining the approval fees for design and maintenance organisations.
— The use of the highest priced product is also a metric that EASA believes will be easier to apply given the large spreads between the three categories it proposes.
— Taken together, these two metrics will be good proxies to the risk level represented by an organisation and the level of workload required by EASA to approve it.
— Applicants will benefit from greater certainty and predictability in determining the fees that are applicable to them.
— Both applicants and EASA will also gain efficiencies by saving on time that is often required from them to determine the scope of the applicant’s organisation to consider in calculating the turnover.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
9 Simplify and adapt to new realities the MTOW fee tier structure for the certification of small fixed-wing aircraft (now horizontal take-off and landing (HTOL) aircraft)
For certification activities related to small fixed-wing aircraft (now HTOL aircraft), fees vary depending on the MTOW of the aircraft. The current F&Cs Regulation provides for a structure of fee tiers as follows (from heaviest to lightest):
— > 150 tonnes;
— 50 to 150 tonnes;
— 22 to 50 tonnes;
— 5.7 to 22 tonnes (including high-performance aircraft (HPA));
— 2.0 to 5.7 tonnes (except HPA);
— < 2.0 tonnes (except HPA);
— very light aircraft, powered sailplanes, sailplanes;
— light sport aeroplanes.
EASA identified three opportunities to simplify and improve the above fee tier structure:
1. The ‘light sport aeroplanes’ category could be merged with the ‘very light aircraft, powered sailplanes and sailplanes’ category.
2. ‘Very light aircraft’ will be easier to scope if it was defined by its MTOW as it is done with heavier categories.
3. Raising the bar of 2.0 tonnes to 2.73 tonnes will make the tier limit consistent with technical requirements (certification rules applicable to aircraft that have an MTOW below 2.73 tonnes are simplified).
Adopt the following simplified fee tier structure:
— > 150 tonnes;
— 50 to 150 tonnes;
— 22 to 50 tonnes;
— 5.7 to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes);
— 2.73 to 5.7 tonnes (including HPA over 1.2 up to 2.73 tonnes);
— 1.2 to 2.73 tonnes (including HPA up to 1.2 tonnes);
— < 1.2 tonnes.
— Simplified fee tier structure that is more predictable and manageable for both applicants and EASA.
— Better coherence with technical requirement categories.
The main impact will be for applicants that apply for the certification of a product whose MTOW is between 2.0 and 2.73 tonnes. EASA observed an unusually low number of applications for fixed-wing aircraft whose MTOW is between 2.0 and 2.73 tonnes. By changing the boundary of 2.0 tonnes to 2.73 tonnes, EASA anticipates an increase in the number of applications for the certification of aircraft within the 2.0–2.73-tonnes range.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
10 Adjust the fees for certification activities for aircraft whose MTOW is between 2.0 (currently 2.73) and 5.7 tonnes to reduce the drastic increase of fee levels
EASA observed an unusually low number of applications for fixed-wing aircraft whose MTOW is between 2.0 (currently 2.73) and 5.7 tonnes. This is most likely due to the fees increasing substantially when an aircraft is classed as having an MTOW above 2 tonnes instead of below. For example, in the current F&Cs Regulation, the fee to issue a type certificate jumps from EUR 13 940 to EUR 263 800 for a fixed-wing aircraft whose MTOW is above 2 tonnes.
Reduce certification fees for fixed-wing aircraft whose MTOW is between 2.0 (currently 2.73 tonnes as per above recommendation) and 5.7 tonnes (see Appendix A for exact proposed fees).
Support the design and certification within EASA’s Member States of small aircraft, in line with EASA’s General Aviation Roadmap.
EASA expects the decrease in fees to attract more demand for certificates in the targeted categories, mitigating the decrease in fee revenues caused by the decrease in fees.
11 Introduce fixed fees for the certification of Flight Simulator Training Devices (FSTD)
Fees levied for the certification of Flight Simulator Training Devices are currently calculated on an hourly rate basis. This creates uncertainty for applicants who do not get a definite view of the fees for the certification until the certification is actually completed. It also increases the administrative burden to manage such fees, both for EASA and the applicants, as EASA needs to keep track of all worked hours in order to be able to issue an accurate invoice, and applicants are required as per their internal policies to monitor and diligently review the hours underlying the invoices received from EASA before paying them.
Introduce new annual flat fees for the certification of Flight Simulator Training Devices, with different prices depending on whether the simulator is a Full Flight Simulator (FFS), a Flight Training Device (FTD) or a Flight and Navigation Procedure Trainer (FNPT).
Taking into consideration further impact assessment, especially in the low range, the fee structure and amounts initially proposed have been revised, introducing a complex/non-complex approach.
The new flat fees are expected to lead to greater fee predictability for the applicants as well as to a lower administrative burden to actually manage their application.
The flat fees have been structured and calculated such that they reflect as best as possible true cost of certification (based on the average number of hours typically dedicated by EASA on such activities), therefore it is not anticipated that applicants will see a big shift in the fees they ultimately pay for these activities.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
12 Introduce fixed fees for the Maintenance Review Board (MRB) activities
Fees levied for the Maintenance Review Board activities are currently calculated on an hourly rate basis. This creates uncertainty and increases the administrative burden of managing those fees, as discussed above for FSTDs.
Introduce new flat fees for the approval of Maintenance Review Board (MRB) activities, with different prices for initial MRB report and revision of MRB report.
The new flat fees are expected to lead to greater fee predictability for the applicants as well as lower administrative burden to actually manage their application.
The flat fees have been structured and calculated such that they reflect as best as possible the cost of approval of Maintenance Review Board activities, based on the experience gained with MRB applications.
13 Introduce fixed fees for the Certification Support for Validation (CSV)
Fees levied for the Certification Support for Validation are currently calculated on an hourly rate basis. This creates uncertainty and increases the administrative burden of managing those fees, as discussed above for FSTDs.
Introduce new flat fees for the approval of Certification Support for Validation activities, with different prices for service packages:
— Individual Service – scope comprised of validation support for RTC, STC and Complex Significant and Significant Major Changes, as well as technical support related to compliance finding activities
— Large - scope comprised of validation support for STC, Major Changes and Repairs applicable to HTOL >5,7t, Large VTOL and Turbine Engines
— Medium - scope comprised of validation support for STC, Major Change and Repairs for other categories than covered by the Large Service Package, and ETSOA
— Small - scope comprised of administrative tasks, without involvement of EASA technical staff
— The new flat fees are expected to lead to greater fee predictability for the applicants as well as lower administrative burden to actually manage their application.
— Service Packages and related F&Cs are differentiated based on higher effort from EASA’s side.
— GA and smaller applicants should benefit from the lower fees of the Medium package.
The flat fees have been structured and calculated to reflect as best as possible current hourly rates charged, based on the experience gained with CSV applications.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
14 Include the cost of Operational Suitability Data (OSD) certification as part of relevant existing flat fees for the certification of products
The fees for the approval of Operational Suitability Data are currently charged on the basis of an hourly rate. This creates uncertainty and increases the administrative burden of managing those fees, as discussed above for FSTDs. Furthermore, OSD has become a compulsory part of the certification of products, and charging separately for this activity has become conceptually illogical.
Include the cost of OSD certification in the relevant existing flat fees, i.e. fees for type certificate, supplemental type certificate and major changes.
The new flat fees are expected to lead to greater fee predictability for the applicants as well as lower administrative burden to actually manage their application.
The change will lead to an increase in the relevant existing flat fees for the certification of products, however applicants will no longer be charged separately for the OSD activity. As a result, applicants will generally not see a difference in the fees they pay for the certification of their products and will benefit from simplified invoicing and fee structure.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
15 Simplify the criteria defining situations where “annual fees for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No 216/2008” (continuous airworthiness fee) are charged on an hourly basis instead of using a flat fee
Continuous airworthiness fees are currently charged on an hourly basis for aircraft of which less than 50 examples are registered worldwide. The objectives of this rule are still valid today, however its application has raised complexities for both applicants and EASA given the potentially high number of sources needed to determine how many aircraft are registered worldwide. These complexities are causing important inefficiencies EASA aims to fix.
Continuous airworthiness fees will be charged on an hourly basis instead of using a flat fee (1) for aircraft of which less than 50 examples are produced or that are out of production for more than 30 years; (2) for engines and propellers of which less than 100 examples are produced or that are out of production for more than 30 years; (3) for European technical Standard Orders (ETSOs) of which less than 200 examples are produced or that are out of production for more than 15 years. Continuous airworthiness fees for European technical Standard Orders (ETSOs) have been adjusted downwards in line with the abolition of reductions applied to the second and subsequent certificate in the same value category. The new rule will also clarify that while it remains the responsibility of the applicant to demonstrate that such criteria are met, applicants will have no more than 1 year after an invoice is issued to make such demonstration in order for the invoice to be retroactively adjusted. Finally, the new rule will provide that in no case the total fees charged for the period in question on an hourly basis can exceed the fees that would have been paid by the same applicant had the continuous airworthiness fees been calculated using a flat fee for that period.
The new rules are expected to greatly simplify the administration of the continuous airworthiness fees for small productions and for aircraft out of production, both for applicants and EASA, saving costs and offering increased efficiencies to both by having the rule criteria application rely on information held by applicants (number of examples produced and time of production ending).
Beyond the efficiency gains, EASA does not expect the new rule to impact the fees currently paid by the majority of applicants that were aimed by the initial rule.
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# Proposed amendment Targeted issues Description of the proposed amendment
Intended benefits Assessment of impact
16 Introduce flat fees for Minor Changes and Minor Repairs for Parts and Non-installed equipments.
Correct an omission in the current F&C Regulation.
Introduction of a flat fee table for minor changes and minor repairs for Parts and Non-installed equipments.
Administrative changes without technical involvement will continue to be charged as administrative reissuance of document.
The new flat fees are expected to offer predictability and certainty for applicants.
The impact is expected to be limited given the low number of applications in this category.
17 Harmonise the interpretation of “number of staff” as headcount for all types of organisation approvals.
“Number of staff” is currently interpreted as headcount for some type of organisations, as FTE for others.
“Number of staff” will be interpreted as headcount for all organisations.
The new interpretation is expected to improve the application of the F&C system.
The change in interpretation might affect the fee categorisation for some organisations, especially DOAs.
D. NEXT STEPS
EASA invited 3200 applicants, i.e. applicants that currently hold or have held at least one certificate from EASA over the past 5 years; 40 RPAS related organisations; Advisory groups (A4A, IATA, European Regions Airline Association, ASD, CANSO, EHA, GAMA, FNAM) to take part in a stakeholder consultation through an online survey. The F&C modification proposal has been revised following the consultation, as reflected in this revised memorandum.
EASA has informed its main advisory bodies, the SAB and MAB, about the main modifications proposed. SAB and MAB have been invited to comment on the proposals.
The European Commission, supported by EASA, is drafting the F&C Regulation for consultation with the EASA Committee in June and October 2019. The European Commission will also consult in that period the EASA Management Board, which will consult the SAB. The new F&Cs Regulation could enter into force by 2020.
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APPENDIX A: PROPOSED PRICE TABLES
Part 1
Tasks charged a flat fee
Table A1
Type Certificates and Restricted Type Certificates for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft
(Formerly Fixed Wing Aircraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Over 150 000 kg 1,890,315 Over 150 tonnes 2,055,230
Over 50 000 kg up to 150 000 kg 1,620,270 Over 50 up to 150 tonnes 1,693,040
Over 22 000 kg up to 50 000 kg 540,090 Over 22 up to 50 tonnes 564,350
Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft)
405,068 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)
420,700
Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft)
279,364 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)
123,130
Up to 2 000 kg (except for High Performance Aircraft) 14,762 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)
15,890
Very Light Aeroplanes, Powered Sailplanes, Sailplanes 7,381 Up to 1.2 tonnes 5,300
Light Sport Aeroplanes 5,539
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Table A2
Type Certificates and Restricted Type Certificates for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)
Current fee structure (adjusted for forecasted inflation until
2020, EUR)
New proposed fee structure (2020 fees, EUR)
Large 491,376 Large 476,100
Medium 196,550 Medium 190,450
Small 24,611 Small 23,850
Very light rotorcraft 24,611 Very light aircraft 23,850
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Table A33
Type Certificates and Restricted Type Certificates for Other Aircraft
Current fee structure (adjusted for forecasted inflation until
2020, EUR)
New proposed fee structure (2020 fees, EUR)
Balloons 7,381 Balloons 7,380
Airships Large 40,909 Airships Large 42,950
Airships Medium 16,362 Airships Medium 16,360
Airships Small 8,186 Airships Small 8,190
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Table A4
Type Certificates and Restricted Type Certificates for Propulsion
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
418,305 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
405,310
Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
278,835 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
270,170
Non turbine engines 36,917 Non turbine engines 36,920
CS-22.H, CS-VLR App. B engines 18,458 CS-22.H, CS-VLR App. B engines 18,460
Propeller for use on aircraft over 5 700 kg MTOW 12,613 Propeller for use on aircraft over 5 700 kg MTOW 12,610
Propeller for use on aircraft up to 5 700 kg MTOW 3,601 Propeller for use on aircraft up to 5 700 kg MTOW 3,600
CS-22J Class Propeller 1,800 CS-22J Class Propeller 1,800
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Table A5
ETSO Authorisation for Parts and Non-installed equipments
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Value above EUR 20,000 9,298 Value above EUR 20,000 9,300
Value between EUR 2,000 and 20,000 5,316 Value between EUR 2,000 and 20,000 5,320
Value below EUR 2,000 3,082 Value below EUR 2,000 3,090
Auxiliary Power Unit (APU) 221,119 Auxiliary Power Unit (APU) 221,120
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Table A7
Supplemental Type Certificates for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft
(Formerly Fixed Wing Aircraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure (2020 fees, EUR)
Complex Standard Simple
Complex Significant
Significant Standard Simple
Over 150 000 kg 63,752 13,608 3,876 Over 150 tonnes 952,500 76,480 16,325 4,650
Over 50 000 kg up to 150 000 kg 38,262 10,887 3,050 Over 50 up to 150 tonnes 680,880 45,900 13,055 3, 655
Over 22 000 kg up to 50 000 kg 25,511 8,165 2,775 Over 22 up to 50 tonnes 378,140 30,600 9,790 3,330
Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft)
15,303 5,443 2.775 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)
290,420 18,355 6,535 3,330
Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft)
4,681 2,150 1,080 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)
153,120 5,610 2,575 1,290
Up to 2 000 kg (except for High Performance Aircraft)
1,970 1,228 614 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)
6,140 1,970 1,230 610
Very Light Aeroplanes, Powered Sailplanes, Sailplanes
307 307 307 Up to 1.2 tonnes 3,630 310 310 310
Light Sport Aeroplanes 233 233 233
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Table A8
Supplemental Type Certificates for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Complex Standard Simple Complex
Significant Significant Standard Simple
Large 49,138 7,371 2,457 Large 321,710 58,945 8,840 2,945
Medium 24,569 4,914 1,970 Medium 188,500 29,475 5,895 2,360
Small 9,828 3,685 1,228 Small 15,080 11,795 4,420 1,475
Very light rotorcraft 1,112 487 307 Very light aircraft 9,610 1,110 490 310
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Table A10
Supplemental Type Certificates for Other Aircraft
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Complex Standard Simple Complex
Significant Significant Standard Simple
Balloons 1,048 487 307 Balloons 3,630 1,050 490 310
Airships Large 12,284 9,828 4,914 Airships Large 37,700 15,970 12,780 6,390
Airships Medium 4,914 3,929 1,970 Airships Medium 15,090 4,910 3,930 1,970
Airships Small 2,457 1,970 985 Airships Small 7,520 2,460 1,970 990
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Table A11
Supplemental Type Certificates for Propulsion
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Complex Standard Simple Complex
Significant Significant Standard Simple
Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
12,284 7,371 4,914 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
190,090 14,735 8,840 5,895
Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
7,371 5,782 3,855 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
185,830 8,840 6,940 4,625
Non turbine engines 3,442 1,536 773 Non turbine engines 34,710 3,440 1,540 770
CS-22.H, CS-VLR App. B engines 1,726 773 371 CS-22.H, CS-VLR App. B engines 17,410 1,730 770 370
Propeller for use on aircraft over 5 700 kg MTOW
2,457 1,228 614 Propeller for use on aircraft over 5 700 kg MTOW
7,020 2,460 1,230 610
Propeller for use on aircraft up to 5 700 kg MTOW
1,843 921 466 Propeller for use on aircraft up to 5 700 kg MTOW
2,140 1,840 920 470
CS-22J Class Propeller 921 466 233 CS-22J Class Propeller 1,080 920 470 230
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Table A12
Supplemental Type Certificates for Parts and Non-installed equipments
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Complex Standard Simple Complex
Significant Significant Standard Simple
Value above EUR 20,000 Value above EUR 20,000
Value between EUR 2,000 and 20,000
Value between EUR 2,000 and 20,000
Value below EUR 2,000 Value below EUR 2,000
Auxiliary Power Unit (APU)
7,371 4,914 2,457 Auxiliary Power Unit (APU)
136,280 7,370 4,915 2,460
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Table A13
Major Changes and Major Repairs for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft
(Formerly Fixed Wing Aircraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Derivatives Complex Standard Simple Model fee*
Complex Significant
Significant Standard Simple
Over 150 000 kg 650,332 53,797 9,880 3,526 Over 150 tonnes 100,000 800,000 78,010 14,330 5,110
Over 50 000 kg up to 150 000 kg
390,242 26,920 7,413 2,266 Over 50 up to 150 tonnes
59,880 479,050 39,030 10,750 3,290
Over 22 000 kg up to 50 000 kg
260,090 21,540 4,946 1,769 Over 22 up to 50 tonnes
39,910 319,280 31,230 7,170 2,560
Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft)
208,094 13,460 2,467 1,769
Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)
31,930 255,450 19,520 3,580 2,560
Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft)
98,487 3,696 1,726 858
Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)
15,110 120,900 5,360 2,500 1,240
Up to 2 000 kg (except for High Performance Aircraft)
3,442 1,356 614 307
Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)
530 4,230 1,360 610 310
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Very Light Aeroplanes, Powered Sailplanes, Sailplanes
2,955 307 307 307 Up to 1.2 tonnes 450 3,630 310 310 310
Light Sport Aeroplanes 2,213 233 233 233
*The model fee covers the addition of a model to the type design and shall be levied per application and model. It must be associated with an application for
standard, significant or complex significant change. In case several changes applied for separately lead to the addition of one model, these changes shall be assessed
altogether in order to determine whether the “complex significant” fee applies.
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Table A14
Major Changes and Major Repairs for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Derivatives Complex Standard Simple Model fee*
Complex Significant
Significant Standard Simple
Large 196,550 36,853 7,371 2,457 Large 30,160 241,280 53,440 10,690 3,560
Medium 122,844 19,655 4,914 1,716 Medium 18,850 150,800 28,500 7,120 2,490
Small 12,284 7,868 3,685 985 Small 1,890 15,080 11,410 5,340 1,430
Very light rotorcraft 7,381 1,048 487 307 Very light aircraft 1,130 9,060 1,050 490 490
*The model fee covers the addition of a model to the type design and shall be levied per application and model. It must be associated with an application for
standard, significant or complex significant change. In case several changes applied for separately lead to the addition of one model, these changes shall be assessed
altogether in order to determine whether the “complex significant” fee applies.
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Table A16
Major Changes and Major Repairs for Other Aircraft
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Derivatives Complex Standard Simple Model fee* Complex
Significant Significant Standard Simple
Balloons 2,955 1,048 487 307 Balloons 450 3,630 1,050 490 490
Airships Large 24,569 9,828 7,371 4,914 Airships Large 3,770 30,160 14,250 10,690 7,120
Airships Medium 9,828 3,929 2,944 1,970 Airships Medium 1,510 12,060 3,930 2,940 1,970
Airships Small 4,914 1,970 1,472 985 Airships Small 750 6,030 1,970 1,470 990
*The model fee covers the addition of a model to the type design and shall be levied per application and model. It must be associated with an application for
standard, significant or complex significant change. In case several changes applied for separately lead to the addition of one model, these changes shall be assessed
altogether in order to determine whether the “complex significant” fee applies.
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Table A17
Major Changes and Major Repairs for Propulsion
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Derivatives Complex Standard Simple Model fee*
Complex Significant
Significant Standard Simple
Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
85,567 6,788 2,499 1,504
Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
13,130 105,040 9,840 3,620 2,180
Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
73,706 3,685 1,250 752
Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
11,310 90,480 5,340 1,810 1,090
Non turbine engines 12,306 1,599 741 371 Non turbine engines 1,890 15,110 1,600 740 500
CS-22.H, CS-VLR App. B engines
6,153 741 371 307 CS-22.H, CS-VLR App. B engines
940 7,550 740 370 370
Propeller for use on aircraft over 5 700 kg MTOW
3,082 1,324 307 307 Propeller for use on aircraft over 5 700 kg MTOW
470 3,780 1,320 500 500
Propeller for use on aircraft up to 5 700 kg MTOW
943 995 307 307 Propeller for use on aircraft up to 5 700 kg MTOW
150 1,160 1,000 470 470
CS-22J Class Propeller 477 498 159 159 CS-22J Class Propeller 73 590 500 160 160
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*The model fee covers the addition of a model to the type design and shall be levied per application and model. It must be associated with an application for
standard, significant or complex significant change. In case several changes applied for separately lead to the addition of one model, these changes shall be assessed
altogether in order to determine whether the “complex significant” fee applies.
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Table A18
Major Changes and Major Repairs for Parts and Non-installed equipments
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Derivatives Complex Standard Simple Model fee*
Complex Significant
Significant Standard Simple
Value above EUR 20,000
Value above EUR 20,000
Value between EUR 2,000 and 20,000
Value between EUR 2,000 and 20,000
Value below EUR 2,000
Value below EUR 2,000
Auxiliary Power Unit (APU)
57,080 3,685 1,228 741 Auxiliary Power Unit (APU)
8,760 70,070 3,690 1,230 740
*The model fee covers the addition of a model to the type design and shall be levied per application and model. It must be associated with an application for
standard, significant or complex significant change. In case several changes applied for separately lead to the addition of one model, these changes shall be assessed
altogether in order to determine whether the “complex significant” fee applies.
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Table A19
Minor Changes and Minor Repairs for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft
(Formerly Fixed Wing Aircraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Over 150 000 kg 943 Over 150 tonnes 1,890
Over 50 000 kg up to 150 000 kg 943 Over 50 up to 150 tonnes 1,890
Over 22 000 kg up to 50 000 kg 943 Over 22 up to 50 tonnes 1,890
Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft) 943 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes) 1,890
Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft) 307 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes) 610
Up to 2 000 kg (except for High Performance Aircraft) 307 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes) 500
Very Light Aeroplanes, Powered Sailplanes, Sailplanes 307 Up to 1.2 tonnes 310
Light Sport Aeroplanes 233
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Table A20
Minor Changes and Minor Repairs for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)
Current fee structure (adjusted for forecasted inflation
until 2020, EUR)
New proposed fee structure (2020 fees, EUR)
Large 487 Large 970
Medium 487 Medium 970
Small 487 Small 970
Very light rotorcraft 307 Very light aircraft 490
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Table A22
Minor Changes and Minor Repairs for Other Aircraft
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Balloons 307 Balloons 490
Airships Large 858 Airships Large 1,720
Airships Medium 487 Airships Medium 970
Airships Small 487 Airships Small 970
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Table A23
Minor Changes and Minor Repairs for Propulsion
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
635 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
1,270
Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
635 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
1,270
Non turbine engines 307 Non turbine engines 610
CS-22.H, CS-VLR App. B engines 307 CS-22.H, CS-VLR App. B engines 370
Propeller for use on aircraft over 5 700 kg MTOW 307 Propeller for use on aircraft over 5 700 kg MTOW 500
Propeller for use on aircraft up to 5 700 kg MTOW 307 Propeller for use on aircraft up to 5 700 kg MTOW 470
CS-22J Class Propeller 159 CS-22J Class Propeller 320
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Table A24
Minor Changes and Minor Repairs for Parts and Non-installed equipments
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Value above EUR 20,000 Value above EUR 20,000 1,860
Value between EUR 2,000 and 20,000 Value between EUR 2,000 and 20,000 1,070
Value below EUR 2,000 Value below EUR 2,000 620
Auxiliary Power Unit (APU) 487 Auxiliary Power Unit (APU) 490
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Table A25
Annual fee for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No
216/2008 for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft (Formerly Fixed Wing Aircraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure (2020 fees, EUR)
EU Design
Non EU Design
EU Design Non EU Design
Over 150 000 kg 1,141,602 408,139 Over 150 tonnes 1,155,160 360,270
Over 50 000 kg up to 150 000 kg 903,221 267,503 Over 50 up to 150 tonnes 975,480 274,490
Over 22 000 kg up to 50 000 kg 272,163 101,982 Over 22 up to 50 tonnes 293,940 110,140
Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft)
44,489 15,112 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)
48,050 16,320
Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft)
4,924 1,726 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)
5,320 1,770
Up to 2 000 kg (except for High Performance Aircraft)
2,457 826 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)
2,460 830
Very Light Aeroplanes, Powered Sailplanes, Sailplanes
1,112 371 Up to 1.2 tonnes
900 370
Light Sport Aeroplanes 826 275
For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments
No reduction applied to the second and subsequent Type Certificates, or Restricted Type Certificates.
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Table A6
Annual fee for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No
216/2008 for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
EU Design Non EU Design EU Design Non EU Design
Large 111,830 35,773 Large 102,930 37,740
Medium 55,915 19,708 Medium 57,190 21,280
Small 22,112 8,165 Small 23,880 8,670
Very light rotorcraft 3,696 1,228 Very light aircraft 3,700 1,230
For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments
No reduction applied to the second and subsequent Type Certificates, or Restricted Type Certificates.
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Table A7
Annual fee for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No
216/2008 for Other Aircraft
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
EU Design Non-EU Design EU Design Non-EU Design
Balloons 1,112 371 Balloons 840 360
Airships Large 3,685 1,228 Airships Large 4,000 1,330
Airships Medium 2,457 815 Airships Medium 2,460 820
Airships Small 1,970 657 Airships Small 1,970 660
For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments.
No reduction applied to the second and subsequent Type Certificates, or Restricted Type Certificates.
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Table A29
Annual fee for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No
216/2008 for Propulsion
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
EU
Design Non EU Design
EU
Design Non EU Design
Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
113,419 33,750 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW
120,090 32,140
Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
56,709 28,222 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW
58,180 27,450
Non turbine engines 1,228 434 Non turbine engines 1,120 140
CS-22.H, CS-VLR App. B engines 614 307 CS-22.H, CS-VLR App. B engines 610 310
Propeller for use on aircraft over 5 700 kg MTOW 921 307 Propeller for use on aircraft over 5 700 kg MTOW 420 220
Propeller for use on aircraft up to 5 700 kg MTOW 466 159 Propeller for use on aircraft up to 5 700 kg MTOW 240 50
CS-22J Class Propeller 233 74 CS-22J Class Propeller 230 70
For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments.
No reduction applied to the second and subsequent Type Certificates, or Restricted Type Certificates.
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Table A30
Annual fee for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No
216/2008 for Parts and Non-installed equipments
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
EU Design Non EU Design EU
Design Non EU Design
Value above EUR 20,000 4,766 1,589 Value above EUR 20,000
2,440 680
Value between EUR 2,000 and 20,000 2,383 794 Value between EUR 2,000 and 20,000
1,290
460
Value below EUR 2,000 1,197 572 Value below EUR 2,000
520 420
Auxiliary Power Unit (APU) 90,015 27,534 Auxiliary Power Unit (APU)
87,880 10,510
For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments.
No reduction applied to the second and subsequent ETSO Authorisation.
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Table A8
Design Organisation Approval – Approval Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
1A 1B 2A
1C 2B 3A
2C 3B
3C 1A 1B 2A
1C 2B 3A
2C 3B
3C
Staff related below 10 14,402 11,331 8,472 5,719 4,427 Staff related below 10 14,400 11,330 8,470 5,720 4,430
10 to 49 40,507 28,932 17,357 11,575 10 to 49 40,510 28,930 17,360 11,580
50 to 399 115,749 86,838 57,821 44,298 50 to 399 179,410 134,600 89,620 68,660
400 to 999 231,497 173,570 144,659 121,785 400 to 999 358,820 269,030 224,220 188,770
1,000 to 2,499 462,995 1,000 to 2,499 717,640
2,500 to 5,000 694,386 2,500 to 5,000 1,076,300
Over 5,000 3,857,937 Over 5,000 5,979,800
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Table A9
Design Organisation Approval – Surveillance Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
1A 1B 2A
1C 2B 3A
2C 3B
3C 1A 1B 2A
1C 2B 3A
2C 3B
3C
Staff related below 10 7,201 5,666 4,236 2,859 2,213 Staff related below 10 7,200 5,670 4,240 2,860 2,210
10 to 49 20,259 14,466 8,684 5,782 10 to 49 20,260 14,470 8,680 5,780
50 to 399 57,821 43,398 28,932 23,150 50 to 399 78,060 58,590 38,930 31,250
400 to 999 115,749 86,838 72,330 63,646 400 to 999 156,260 117,230 97,650 85,920
1,000 to 2,499 231,497 1,000 to 2,499 312,520
2,500 to 5,000 347,246 2,500 to 5,000 468,780
Over 5,000 1,929,498 Over 5,000 2,604,820
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Table A33
Alternative Procedures of Design Organisation Approval
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
1A (Type certification) 7,943 1A (Type certification) 7,940
1B (Type certification – Continued airworthiness only) 3,177 1B (Type certification – Continued airworthiness only) 3,180
2A (Supplemental type certificates (STC) and/or major repairs) 6,354 2A (Supplemental type certificates (STC) and/or major repairs) 6,350
2B (STC and/or major repairs – Continued airworthiness only) 2,648 2B (STC and/or major repairs – Continued airworthiness only) 2,650
3A (ETSOA) 6,354 3A (ETSOA) 6,350
3B (ETSOA – Continued airworthiness only) 3,177 3B (ETSOA – Continued airworthiness only) 3,180
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Table A34
Product Organisation Approval – Approval Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Turnover (EUR) < 1,000,000
11,077 Highest Priced Product
Below 5,000 EUR
Highest Priced Product Between 5,000 and
100,000 EUR
Highest Priced Product Above 100,000 EUR
Between 1,000,000 and 4,999,999 61,422 Staff related below 100
20,650 39,710 55,600
Between 5,000,000 and 9,999,999 218,578 100 and 499 31,770 63,540 111,200
Between 10,000,000 and 49,999,999 327,866 500 and 999 59,570 119,140 238,280
Between 50,000,000 and 99,999,999 379,122 1,000 and 4,999 158,850 317,700 794,250
Between 100,000,000 and 499,999,999 442,238 5,000 and 20,000 595,670 1,191,380 2,779,880
Between 500,000,000 and 999,999,999 775,294 Over 20,000 992,810 1,985,630 3,971,250
Over 999,999,999 2,948,256
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Table A35
Product Organisation Approval – Surveillance Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Turnover (EUR) < 1,000,000
7,995 Highest Priced Product
Below 5,000 EUR
Highest Priced Product Between 5,000 and 100,000
EUR
Highest Priced Product Above 100,000 EUR
Between 1,000,000 and 4,999,999 38,961 Staff related below 100
13,770 26,480 37,070
Between 5,000,000 and 9,999,999 51,944 100 and 499 21,180 42,360 74,120
Between 10,000,000 and 49,999,999 77,942 500 and 999 39,710 79,430 158,850
Between 50,000,000 and 99,999,999 184,266 1,000 and 4,999
105,900 211,800 529,500
Between 100,000,000 and 499,999,999 245,688 5,000 and 20,000
397,130 794,290 1,853,250
Between 500,000,000 and 999,999,999 491,376 Over 20,000 625,000 1,323,750 2,647,500
Over 999,999,999 2,337,213
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Table A36
Maintenance Organisation Approval – Initial Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Staff related below 5 3,696 Staff related below 5 3,700
5 to 9 6,153 5 to 9 6,150
10 to 49 15,885 10 to 49 24,620
50 to 99 25,416 50 to 99 39,400
100 to 499 33,973 100 to 499 52,660
500 to 999 46,914 500 to 999 72,720
Over 999 65,870 Over 999 102,100
Technical Rating A1 13,534 Technical Rating A1 20,980
Technical Rating A2 3,082 Technical Rating A2 4,780
Technical Rating A3 6,153 Technical Rating A3 9,540
Technical Rating A4 614 Technical Rating A4 950
Technical Rating B1 6,153 Technical Rating B1 9,540
Technical Rating B2 3,082 Technical Rating B2 4,780
Technical Rating B3 614 Technical Rating B3 950
Technical Rating C 614 Technical Rating C 950
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Table A37
Maintenance Organisation Approval – Surveillance Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Staff related below 5 2,828 Staff related below 5 2,830
5 to 9 4,924 5 to 9 4,920
10 to 49 12,708 10 to 49 15,250
50 to 99 25,416 50 to 99 30,500
100 to 499 33,973 100 to 499 40,770
500 to 999 46,914 500 to 999 56,300
Over 999 65,870 Over 999 79,000
Technical Rating A1 13,534 Technical Rating A1 16,240
Technical Rating A2 3,082 Technical Rating A2 3,700
Technical Rating A3 6,153 Technical Rating A3 7,380
Technical Rating A4 614 Technical Rating A4 740
Technical Rating B1 6,153 Technical Rating B1 7,380
Technical Rating B2 3,082 Technical Rating B2 3,700
Technical Rating B3 614 Technical Rating B3 740
Technical Rating C 614 Technical Rating C 740
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Table A38
Maintenance Training Organisation Approval – Approval Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Staff related below 5 3,696 Staff related below 5 3,700
Between 5 and 9 10,463 Between 5 and 9 10,460
Between 10 and 49 22,514 Between 10 and 49 22,510
Between 50 and 99 43,747 Between 50 and 99 43,750
Over 99 57,610 Over 99 57,610
Fee for the second and subsequent additional facility 3,526 Fee for the second and subsequent additional facility 3,530
Fee for second and subsequent additional training course 3,526
Fee for second and subsequent additional training course
3,530
Fee for training course approval Fee for training course approval 3,530
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Table A39
Maintenance Training Organisation Approval – Surveillance Fee
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Staff related below 5 2,828 Staff related below 5 2,830
Between 5 and 9 8,123 Between 5 and 9 8,120
Between 10 and 49 20,820 Between 10 and 49 20,820
Between 50 and 99 34,661 Between 50 and 99 34,660
Over 99 52,950 Over 99 52,950
Fee for the second and subsequent additional facility 2,648 Fee for the second and subsequent additional facility 2,650
Fee for second and subsequent additional training course Fee for second and subsequent additional training course
Fee for training course approval 3,526 Fee for training course approval
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Table A40
Continuing Airworthiness Management Organisation Approval
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
Approval fee 52,950 Approval fee 52,950
Surveillance fee 52,950 Surveillance fee 52,950
Initial Approval Surveillance Initial Approval Surveillance
Technical rating A1 (airplanes above 5.7 ton)
13,238 13,238 Technical rating A1 (airplanes above 5.7 ton)
13,240 13,240
Technical rating A2 (airplanes below 5.7 ton)
6,619 6,619 Technical rating A2 (airplanes below 5.7 ton)
6,620 6,620
Technical rating A3 (helicopters)
6,619 6,619 Technical rating A3 (helicopters)
6,620 6,620
Technical rating A4 (all others)
6,619 6,619 Technical rating A4 (all others)
6,620 6,620
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Table A10
Acceptance of approvals equivalent to ‘Part 145’ and ‘Part 147’ approvals in accordance with applicable bilateral agreements
Current fee structure (adjusted for forecasted inflation until 2020, EUR)
New proposed fee structure
(2020 fees, EUR)
New approvals, per application and per period of first 12 months 1,800 New approvals, per application and per period of first 12 months 1,800
Continuation of existing approvals, per period of 12 months 900 Continuation of existing approvals, per period of 12 months 900
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Table A42
Third Country Operator
New proposed fee structure
(2020 fees, EUR)
On-site visit* 19,000
Technical meeting in Cologne 10,000
*Travel cost and travel time charged using F&C regulation provisions for audits outside the EU
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Table A44
Flight Simulator Training Devices (FSTD) – Approval Fee
Charged per application
New proposed fee structure
(2020 fees, EUR)
Flat fee per location 12,350
Single Engine / Aircraft
Configuration Double Engine / Aircraft
Configuration 3+ Engine / Aircraft Configuration
Full Flight Simulator (FFS) 32,110 39,520 45,940
Flight Training Device (FTD) 13,590 16,070 22,480
Single Engine Piston or equivalent Multi Engine Piston or equivalent
Single Multi Engine
turboprop or turbofan or equivalent
Flight Navigation Procedure Trainer (FNPT)
9,880 13,590 18,530
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Table A45
Flight Simulator Training Devices (FSTD) – Surveillance Fee –
Charged on an annual basis
New proposed fee structure
(2020 fees, EUR)
Flat fee per location (complex) 5,560
Flat fee per location (non-complex) 2,780
Single Engine / Aircraft
Configuration Double Engine / Aircraft
Configuration 3+ Engine / Aircraft Configuration
Full Flight Simulator (FFS) 8,650 11,120 13,590
Flight Training Device (FTD) 4,940 6,180 6,670
Single Engine Piston or equivalent Multi Engine Piston or equivalent
Single Multi Engine
turboprop or turbofan or equivalent
Flight Navigation Procedure Trainer (FNPT)
3,710 4,940 7,410
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Table A46
Flight Simulator Training Devices (FSTD) – Extended Evaluation Programme (EEP)
Charged on an annual basis
New proposed fee structure
(2020 fees, EUR)
Flat fee per location (complex) 11,120
Flat fee per location (non-complex) 5,560
EEP 3 years Single Engine / Aircraft
Configuration
Double Engine / Aircraft
Configuration 3+ Engine / Aircraft Configuration
Full Flight Simulator (FFS) 3,870 4,860 6,010
Flight Training Device (FTD) 2,310 2,890 3,380
Single Engine Piston or equivalent Dual Engine Piston or equivalent
Single Multi Engine
turboprop or turbofan or
equivalent
Flight Navigation Procedure Trainer
(FNPT) 1,900 2,310 3,300
EEP 2 years Single Engine / Aircraft
Configuration
Double Engine / Aircraft
Configuration 3+ Engine / Aircraft Configuration
Full Flight Simulator (FFS) 5,070 6,430 7,910
Flight Training Device (FTD) 2,970 3,710 4,200
Single Engine Piston or equivalent Dual Engine Piston or equivalent Single Multi Engine
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turboprop or turbofan or
equivalent
Flight Navigation Procedure Trainer
(FNPT) 2,350 2,970 4,330
Table A47
Certification Support for Validation (CSV)
Individual Service Service Package
Hourly rate Large 2,500
Medium 1,000
Small 250
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Table A48
Maintenance Review Board (MRB) – Initial Approval and revisions
Initial MRB report Revision of MRB report
350,000 Low activity project 10,000
Standard activity project 90,000
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Part 2
Certification tasks or services charged on an hourly basis
Table A49
Certification tasks or services charged on an hourly basis
Hourly rate
Applicable hourly rate [EUR/h] 247 (*)
(*) including travel cost within the Member States
Hourly basis according to the tasks concerned2:
Production without approval Actual number of hours
Transfer of certificates Actual number of hours
Approved Training Organisation certificate Actual number of hours
Aero-medical Centre certificate Actual number of hours
ATM-ANS organisation certificate Actual number of hours
Air Traffic Controller Training Organisation certificate Actual number of hours
EASA Acceptance of Operational Evaluation Board Reports Actual number of hours
Other Special FSTD activities Actual number of hours
Approval of flight conditions for Permit to fly 3 hours
Alternative Methods of Compliance to AD's 4 hours
2 This is a non-exhaustive list of tasks. The list of tasks in this Part is subject to periodical revision. Non-inclusion of a task to this Part should not be automatically construed as
indicating that the task cannot be performed by the European Aviation Safety Agency.
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FAA Basic STC one serial number 2 hours
Administrative reissuance of document 1 hour
Capability Check 1 hour
Export certificate of airworthiness (E-CoA) for CS 25 aircraft 6 hours
Export certificate of airworthiness (E-CoA) for other aircraft 2 hours
Part III
Charges for appeals
Table A50
Charges for appeals
Charges for appeals shall be calculated as follows: fixed charge shall be multiplied by the coefficient indicated for the corresponding charge category for
the person or organisation in question
Fixed charge 10,000 EUR
Charge category for natural persons Coefficient
0,1
Charge category for legal persons, according to financial turnover of the appellant in euro Coefficient
less than 100,001 0,25
between 100,001 and 1,200,000 0,5
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between 1,200,001 and 2,500,000 0,765
between 2,500,001 and 5,000,000 1
between 5,001 and 50,000,000 2,5
Charge category for legal persons. according to financial turnover of the appellant in euro Coefficient
between 50,000,001 and 500,000,000 5
between 500,000,001 and 1,000,000,000 7,5
over 1,000,000,000 10
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APPENDIX B: MAIN OPTIONS CONSIDERED BUT NOT RETAINED
Adjusting fees for all F&Cs activities with a blanket increase
EASA could increase all F&Cs by applying a blanket percentage increase to all fees. The impact for each
percentage point increase would amount to approximately EUR 1 m per annum.
Advantages
The advantage of this solution is its simplicity and uniformity, as well as relative ease of implementation. Such
amendment could also be adopted irrespective of any changes to the F&Cs structure of tiers. Provided that the
increase is moderate, the solution would not be likely to attract strong opposition.
Disadvantages
One-off price increase is unlikely to improve sustainability of EASA’s budget over time and the process of
amending the F&Cs Regulation would have to be replicated with each following increase. The increase would
make the financial viability of EASA very sensitive to volume mix change, knowing that some activities are loss-
making. Additionally, if the increase is significant, applicants are likely to resist the changes.
Introducing a fast-track process
EASA could introduce a fast-track service for its applicants — it could charge an extra fee for a guarantee to the
applicant that a certification application will be dealt in priority to other applications, which is a common and
generally accepted service in other areas, such as passports or visas.
Under this new system, EASA would not commit to a specific turnaround time, given EASA’s primary focus on
safety; however, fast-track services would increase the likelihood of the applicant getting a swifter response
from EASA.
Advantages
Introducing a fast-track service could provide faster services to applicants that value speed of response the most,
improving the quality of service EASA provides to its applicants.
Disadvantages
In order to prioritise work for requests for fast-track services, EASA would have to increase its internal work
capacity (in order to work quicker on those requests), otherwise the logical consequence will be that requests
for non-fast-track services will be dealt with at a lower speed. This would mean that unless EASA is indeed able
to increase its capacity internally or through additional outsourcing, the applicants that will typically ‘suffer’
from a decreased quality of service are those that are less willing or unable to pay for such fast-track service,
and it is expected that these applicants, more often than not, are ‘smaller’ applicants. In other words, there is a
high likelihood that such solution would penalise ‘smaller’ applicants at the expense of ‘large’ applicants.
Furthermore, there is a risk that the fast-track service may lead to the perception from the public that whatever
fast-tracked work done by EASA may have been done quicker and to lower quality standards (even if, in fact, the
fast-track service would only have an impact on prioritisation of work). This could lead large manufacturers as
well to shy away from this service: if there was ever an accident involving a product that was certified under the
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fast-track scheme, the risk of negative public perception of the safety quality standards could affect the applicant
as well.
Adopt a purely hourly rate approach
EASA could change the overall F&Cs structure for one based entirely on hourly rate. This means that EASA would
levy fees from applicants based on the number of hours spent. The same hourly rate could be used for all
certification activities, or a different hourly rate could be used depending on the applicant (e.g. a cheaper rate
for ‘small’ applicants) and the type of work (e.g. a more expensive rate for more complex work).
Advantages
An F&Cs system based purely on an hourly rate could be described as the ‘perfect cost-reflective system’. This
approach would eliminate the need to set and adjust different fixed fees for all products and organisations that
EASA certifies and approves, and could fully accommodate new technologies. This approach would mirror that
used by some NAAs.
Disadvantages
An hourly rate approach was used in the past by EASA, but it decided to move away from that system for reasons
that still appear to be valid today. Indeed, despite the transparency of hourly rates, applicants have low
predictability of the total fee they have to pay for certification and approval activities. This is especially important
for ‘small’ applicants for whom EASA’s F&Cs may constitute important regulatory barriers to enter their
respective markets, and especially an issue for very large certification undertakings such as type certificates.
Additionally, the accuracy of fees relies heavily on all EASA staff accurately tracking the hours they dedicate to
any given activity, with the need to specifically attribute those hours to specific applicants (which can be a
challenge sometimes when work relates to more than one applicant). Finally, applicants are often required (for
internal audit purposes) to confirm the accuracy of hours charged by EASA before they can pay any invoice
issued by EASA to them, which adds to the administrative burden of applying the system for both sides.
Calculate fees as a percentage of product value or organisation turnover
EASA could consider changing the overall F&Cs structure by setting F&Cs based on the financial value of the
product or the turnover of the organisation concerned.
For product certification, initial fees could be calculated based on, for example, the catalogue price of an aircraft,
and continuous certification fees could be calculated based on sales revenues on that aircraft. This would replace
the current structure where the MTOW of the aircraft is typically used as a basis for setting fees.
Organisational approvals could be priced based on organisation turnover. This would replace the current
structure where the number of staff is typically used as a basis for setting fees, except for Product Organisation
Approvals that are currently charged based on turnover.
Advantages
The value of a product or turnover of an organisation can be said to be a good proxy to complexity and related
risks, and to the work typically required by EASA to certify or approve such product or organisation. An F&Cs
structure based on value also removes the need to regularly update the F&Cs system in line with new
technologies and innovations, as well as with inflation: by calculating fees as a per cent (%) of the value/turnover,
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the approach can be applied to any type of product or organisation, even those that were not considered at the
time the F&Cs system was implemented.
Disadvantages
Such system would reduce the predictability of EASA’s revenues, and make them more dependent on industry
trends (e.g. if industry moves to cheaper products, EASA’s revenues would be directly impacted even if the
workload is constant). Another difficulty in implementing this model would stem from the fact that certification
typically precedes the phase of product development when the catalogue price is determined, hence making it
challenging for both the organisation and EASA to determine the value off which the fee should be calculated.
The same holds true for new organisations. In addition, this model would not be suitable for activities related to
modifications, because there is no catalogue price for those services. Finally, applicants may perceive this as a
revenue tax, ‘punishing’ them for being successful in their business, which could make them resistant to such a
change in the F&Cs structure.
Set fees based on complexity of product or organisation
EASA could adopt F&Cs based on the complexity of the product or organisation. Such approach is already used
for some activities, such as major changes (for which fees vary depending on whether the change is ‘simple’,
‘standard’ or ‘complex’).
Advantages
Product or organisation complexity could be described as a good proxy to workload for EASA (e.g. the more
complex a product is, the more time-consuming for EASA its certification typically is).
Disadvantages
The definition and interpretation of complexity criteria could become quite challenging for some products and
organisations. In the case of major changes, the complexity criteria actually tie up to technical criteria, which
makes the determination of complexity a relatively straightforward and objective process. Defining complexity
criteria for all products and organisations, however, could become quite challenging. Used as a price basis,
criteria would need to be created and reflected in the Regulation, and creating such a definition is likely to prove
itself a challenging task. Complexity could also be said to ‘not tell the whole story’: while a more complex product
does indeed take more time to certify, other drivers of workload include the size of the product, the number of
systems, etc., which may or may not be considered as part of a complexity metric.
Introduce risk-based pricing for all fees
EASA is currently changing the approach to the certification of products by introducing risk-based principles to
determine the ‘level of involvement’ (LoI) of EASA. Such ‘LoI’ approach will allow EASA to eventually spend less
time on products that are deemed to be low risk, and spend more time on others. One option would be to adopt
fees that are also determined by an assessment of risk of the product or the organisation, thus allowing fee
levels to be adapted in line with the workload EASA will eventually dedicate to certification and approval
activities.
Advantages
If workload for EASA will in the future vary based on risk through the ‘LoI’ approach, then determining fees based
on risk would allow them to be also aligned with workload, thus achieving the goal of ensuring that fees are
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cost-reflective. Such system would also reward good applicant behaviour towards developing safe products,
because the certification of low-risk products would lead to lower fees. Finally, determining fees based on risk
level would make them fully adaptable to new technologies, as risk-assessment criteria could be designed to
apply to any product or organisation, even new ones not known to EASA when the F&C Regulation will enter
into force.
Disadvantages
There is inherent subjectivity in the process of assessing the risk of a product or organisation, and such
subjectivity could drive non-negligible disagreements between applicants and EASA regarding the level of risk
that a product or organisation represents. While such subjectivity can be structured using clear principles and
guidelines, this will require EASA’s ‘LoI’ approach to be fully developed and implemented — at this time,
however, it is still in a pilot phase. Until EASA’s ‘LoI’ approach is further defined, the level of uncertainty it may
lead to for both applicants and EASA is such that it is deemed not advisable at this time to determine fees on
that basis.
Introduce a continuous F&Cs structure
In contrast to the current ‘lockstep’ approach, EASA could move to a continuous system of F&Cs levels. That
would replace the large ‘jumps’ between the current F&Cs tiers with smaller, proportionate increases.
Advantages
This approach may seem fairer to applicants who fall just above a certain threshold and in result are required to
pay significantly more than the ones who fall just below the threshold, despite the only slight difference in the
products.
Disadvantages
A continuous F&Cs structure requires replacing the tiers, which are easy for applicants to apply, by a
mathematical formula which may prove to be significantly more complicated. Also, the continuous pricing
approach may not be beneficial to applicants if, looking at the facts, the products certified and the organisations
approved by EASA do not fall close to a limit between two price tiers, such that the problem of an important
price jump caused, for example, by the increase of the MTOW of a product by only a few kilogrammes does not
apply.
Introduce a fee table for RPASs
The Agency considered introducing a fee table for RPASs based on the use cases.
Advantages
Introducing a fee table based on use cases would increase predictability for the RPASs applicants and increase the cost-reflectivity compared to the current approach of charging by hourly fee.
Disadvantages
Since the RPASs industry is rapidly changing, the basis of use cases was considered not sustainable due to risk of quick outdate. The Agency considered another basis for the fee tables, however the industry is evolving too rapidly to introduce a proposal which would be sustainable over time and adequately address the issues of cost-reflectivity as well as be based on risk.
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Introduce a charge for TCOs
The Agency initially proposed to levy a flat fee for the authorisation and continuous monitoring of TCOs based on the total fleet size and the category of aircraft the TCO flies.
Advantages
Charging the TCOs for the services they receive would be reflective of the workload this activity generates for the Agency, and would help to minimise the carelessly prepared applications, which cause significant amount of additional activity for the Agency and are not paid for. This would also help to alleviate current situation which is unfair to other applicants which need to pay fees for the certification and approval services EASA provides to them.
Disadvantages
The industry pointed towards the risk of retaliation from third countries which would impact the European operators.
Other options
Other options were considered too but, for the reasons already mentioned, disregarded based on an initial
conclusion that the new structure would not be an improvement compared to the current F&Cs system.
— Bundling of services into packages which applicants would be able to purchase in advance at a lower cost: due to the difficulty in determining the level of charges, this solution has not been further considered.
— Membership fee in exchange for an unlimited number of certifications: due to lack of cost-reflectivity, this solution has not been further considered.
— Insurance model (similar to that of an insurance company policy) whereby applicants with good track records and no incidents would be rewarded through lower fees, whereas applicants with no good track records would see their fees increasing. However, this situation would create a financial incentive for applicants not to report accidents and incidents, in fear of this leading to higher fees for them. Due to the fact that EASA wants to encourage applicants to fully report all accidents and incidents for EASA to fully document and learn from these, such financial disincentive to reporting is not desirable.
— Partial financing of rulemaking by applicants, in replacement for EU subsidies: due to the actual or perceived risk of conflict of interests (since EASA would be developing rules which those that finance their development must comply with), the solution has not been further considered.
— Fee model based on performance, which would entail ‘success fee’ in case of certification being granted: due to lack of cost-reflectivity, this solution has not been further considered.
— Auctioning system of selling certification capacity periodically to the best offer: due to lack of cost-reflectivity of the system, this solution has not been further considered.
— Dynamic model in which fees would vary based on resource capacity of EASA or the applicants’ willingness to pay: due to lack of cost-reflectivity of the system, this solution has not been further considered.
— Volume discount, i.e. a rebate to applicants based on volume of certifications and/or approvals: since this model would go against the need for EASA to set fees that also reflect each applicant’s ability to pay, and applicants that typically have the highest ability to pay are also the ones that would benefit from volume discounts, this solution has not been further considered.
— Capacity commitment, i.e. a rebate to applicants that can commit upfront to a certain volume of work to EASA: since this model would also go against the need for EASA to set fees that also reflect each applicant’s ability to pay, and applicants that typically have the ability to commit to large capacity purchase are also the ones that would benefit from volume discounts, this solution has not been further considered.
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APPENDIX C:
Simple Standard Significant Complex Significant
EASA Supplemental Type Certificate (STC)
STC, major design change, or repair, only involving current and well-proven justification methods, for which a complete set of data (description, compliance check-list and compliance documents) can be communicated at time of application, and for which the applicant has demonstrated experience, and which can be assessed by the project certification manager alone, or with a limited involvement of a single discipline specialist
All other STC, major design changes or repairs
Significant’ is defined in paragraph 21.A.101 (b) of the Annex I to Regulation (EC) No 748/2012 (and similarly in FAA 14CFR 21.101 (b)).
‘Complex Significant Change’ is any significant change (ref. GM 21.A.101 of the Annex I to Regulation (EC) No 748/2012) involving at least 2 reasons justifying its classification as significant (examples of criteria as per this GM: change in the general configuration, change to the principles of construction, assumptions used for certification have been invalidated) or
Any significant change involving 2 or more examples described as significant change (column ‘Description of change’ Tables in Appendix 2 to GM 21.A.101 of the Annex I to Regulation (EC) No 748/2012).
EASA major design changes
EASA major repairs
N/A N/A