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Regulatory Hot Topics

International Operations Regulatory FAQ

If you have questions about requirements for international operations, you aren’t alone. NBAA fields dozens of inquiries on the topic every month.

“The NBAA staff receives a lot of questions about international operations, but these three are without a doubt the most common,” said Brian Koester, NBAA’s director of flight operations and regulations.

  • Which class of medical certificate do I need to fly internationally?
  • Do I have to be under 65 years old?
  • What letters of authorization (LOAs) do I need?

While medical certification requirements can vary from one country to another, it’s best to assume each country complies with ICAO standards. In general, this means ATP- and commercial-rated pilots should hold a Class 1 medical certificate.

Maximum age limitations depend on the type of operation and have little direct impact on Part 91 operations. Crew members who are 65 and older may act as PIC of an aircraft conducting Part 91 operations on international flights.

For commercial operations (i.e., those conducted for renumeration or hire, including Part 135 flying), an aviator in a single-pilot operation may not be 60 years or older. In the case of commercial operations with more than one pilot, both pilots must be under 65 years of age.

“Which LOAs are required for international operations is the most complex question because the answer depends in part on how a particular aircraft is equipped, the navigation methods used and the type of operation – commercial or private,” said Koester. “It’s best to consult with an international trip planning support company to ensure compliance with applicable LOAs.”

However, Koester says the following LOAs are fairly common for Part 91 international operations:

A056 Data Link Communications requires Part 91 operators to use data link in oceanic and remote continental airspace. Some countries also require specific data link approval. This generally applies to aircraft operating at FL290 and above in the ICAO NAT Region.

B036 Oceanic and Remote Continental Navigation Using Multiple Long-Range Navigation Systems (LRNS) is required if an operator will be operating in airspace that requires RNP-2, 4 or 10 authorization and is required for unrestricted operations in the North Atlantic.

While B036 authorizes use of multiple long-range navigation systems, B054 Class II Navigation Using Single Long-Range Navigation Systems (S-LRNS) is used to authorize RNP-10 operations using a single LRNS in specified geographic areas. The process to apply for B054 authorization is like that for B036. However, operations under B054 in North Atlantic High-Level Airspace (NAT HLA) with S-LRNS are limited to the special routes (e.g., Blue Spruce routes).

B039 Operations in North Atlantic High-Level Airspace (NAT HLA) is required for all operators in the airspace known as NAT HLA, formerly called North Atlantic (NAT) Minimum Navigation Performance Specifications (MNPS) airspace. NAT HLA is defined as the airspace between FL285 and FL420 within the oceanic control areas of Bodo Oceanic, Gander Oceanic, New York Oceanic East, Reykjavik, Santa Maria and Shanwick, excluding the Shannon and Brest Ocean Transition Areas.


Review NBAA’s international operations resources at nbaa.org/intl.

Industry Challenge

International operations can be complex, requiring compliance with regulations in multiple countries. Business aircraft operators need to stay up to date on the latest requirements.

NBAA Response

NBAA and its International Operations Committee stay on top of policy and regulatory changes to help member companies remain compliant. The NBAA International Operators Conference provides the ultimate business aviation international operations educational opportunity each March.

Quick Poll

Question 1

Which of the following presents the biggest challenge in the international regulatory environment?
  • The frequency of changes to international regulations32.73%
  • Conflicting requirements between the FAA and other international regulators41.82%
  • Lack of experience in international operations25.45%

Question 2

How much international flying do you plan to do in 2022?
  • Much less than in 20218.05%
  • Less than in 20214.60%
  • About the same as in 202118.39%
  • More than in 202141.38%
  • Much more than in 202127.59%

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