EASA TCO AUTHORISATION · Aero Support Group FZCO · Updated 22 October 2026
What is an EASA TCO authorisation?
A third country operator is an operator whose State of the operator functions are not carried out by an EU Member State or EASA. Under Regulation (EU) No 452/2014, as amended by Delegated Regulation (EU) 2023/659, such an operator may only conduct commercial air transport into, within or out of the EU if it complies with Part-TCO (Annex 1) and holds an authorisation issued by EASA under Part-ART (Annex 2).
EASA guidance on TCO.100 clarifies the scope:
- A technical stop in the EU (for example refuelling or crew change) as part of a CAT flight requires a TCO authorisation. Using an EU aerodrome only as an alternate for a diversion does not.
- An operator that wet-leases out aircraft needs the authorisation for the aircraft under its AOC that fly to the EU. With a dry lease, the obligation sits with the operator that dry-leases the aircraft in.
- Aircraft used under a code-share only need it when they perform the CAT flight to the EU.
- General aviation, State flights such as military or police, ferry and delivery flights, and specialised operations fall outside the TCO scope, although specialised operations may need Member State approval.
The TCO authorisation is a safety authorisation. Operating permits and traffic rights remain a matter for the Member States.
What does Part-TCO require of the operator?
- TCO.200: compliance with the applicable ICAO standards, in particular Annexes 1, 2, 6, 8, 18 and 19, with EASA safety directives and with the scope and privileges of the TCO authorisation. Each aircraft needs a certificate of airworthiness issued or validated under Annex 8, and accidents must be reported to EASA without undue delay, including those involving aircraft not flown to the EU.
- TCO.115: access for EASA and Member State inspectors to board aircraft at any time for document checks and ramp inspections, and access to the operator’s facilities and documents, including subcontracted activities.
- TCO.205 to TCO.215: the navigation, communication and surveillance equipment required in EU airspace, valid documents and manuals on board, and production of those documents on request.
Where the AOC operations specifications and the TCO authorisation differ, the more limiting one applies. Approvals granted by the State of the operator, such as dangerous goods, low-visibility operations, RVSM, EDTO, RNP-AR or EFB, can be used unless EASA has limited them.
How the application and EASA assessment work
Under TCO.300 the operator applies at least 30 days before the intended start of operations, in the form EASA establishes. The application includes the AOC and operations specifications, the company registration, the proposed start date, type and area of operation and, for aircraft not registered in the State of the operator, lease details and any Article 83bis agreement.
The application only counts as submitted once the complete set of information has been received. EASA then registers the operator in its TCO web application and sends an electronic questionnaire. Under ART.200 the initial assessment takes 30 days from receipt of all required documents, extended for the duration of any further assessment or audit. EASA applies a risk-based approach, supported by a TCO model that weighs data on both the operator and its State, to decide how deep that assessment goes.
EASA issues the authorisation (ART.210) when it is satisfied that the operator holds a valid AOC, is authorised by its State to operate to the EU, complies with Part-TCO, has communicated transparently and corrected any non-compliance in time, is not subject to an EU operating ban, and when there is no evidence of major deficiencies in its State’s ability to certify and oversee it.
After authorisation: monitoring, changes and continued validity
- Monitoring: EASA reviews each authorised operator at intervals not exceeding 24 months and uses ramp inspection results and other safety data between reviews.
- Changes (TCO.315): changes affecting the authorisation need prior approval, applied for at least 30 days before implementation. Typical examples are adding an aircraft type with a different ICAO type designator, moving the principal place of business to another State, or a merger or takeover. Other changes, such as a new AOC number, a name change, cessation of operations or enforcement measures by the operator’s authority, must be notified before they take effect.
- Continued validity (TCO.320): the authorisation stays valid while the operator remains compliant, keeps a valid AOC, gives EASA access, is not banned, can substantiate its intention to keep operating to the EU and operates at least one aircraft under the authorisation.
- Findings (TCO.325): the operator must identify the root cause, submit a corrective action plan and demonstrate implementation within the agreed period. A level 1 finding leads EASA to limit or suspend the authorisation.
- One-off notification flights (TCO.305): humanitarian and air ambulance flights can start on notification, for up to 12 weeks, provided the operator applies for a full authorisation within 14 days. This option can be used once every 24 months.
Where TCO applications run into difficulty
In our work with third country operators, the same issues come up repeatedly:
- An incomplete application, so EASA’s 30-day clock never starts.
- Differences between the AOC and operations specifications, the actual fleet and the approvals claimed.
- Questionnaire answers on SMS, flight data analysis or dangerous goods that the operator cannot support with records when EASA asks for evidence.
- Corrective action plans that treat the symptom and miss the root cause.
- Ramp inspection findings and safety performance data that raise EASA’s risk assessment of the operator.
- Changes such as new aircraft types or leases introduced without the required prior approval.
How ASG supports TCO applicants and holders
- Readiness assessment against Part-TCO and the ICAO Annexes referenced in TCO.200, with a prioritised action plan.
- Application and questionnaire preparation, with every answer backed by documentary evidence from the operator’s manuals and records.
- SMS, quality and safety data brought to the level EASA expects under Annex 19 and Annex 6.
- Preparation for EASA further assessments and audits, including mock interviews and evidence packages.
- Findings and corrective action plans built on root cause analysis.
- Change management for new aircraft types, leases and AOC changes.
- Continuous compliance through RADAR: a 24/7 dedicated consultant, monthly compliance reviews, regulatory alerts and preparation for EASA’s periodic reviews.
Airlines flying to the United Kingdom need a separate UK CAA TCO authorisation; see our UK CAA TCO consulting. IOSA registration and a strong ramp inspection record support a TCO application, though they do not replace Part-TCO compliance; see IOSA audit preparation.
Conclusion
An EASA TCO authorisation rests on two things: a complete, consistent application and an operation that can show compliance with Part-TCO and the ICAO Annexes when EASA looks closely. The work continues after authorisation, through changes, findings and EASA’s periodic reviews. ASG supports third country operators at every stage. Contact us for a TCO readiness assessment.
Frequently asked questions
TCO stands for Third Country Operator: an airline whose AOC is issued by a State outside the EU or EASA system. A TCO needs an EASA TCO authorisation under Regulation (EU) No 452/2014 before it can fly commercial air transport into, within or out of the EU.
Any operator whose State of the operator is outside the EU and EASA system and that conducts commercial air transport into, within or out of the EU, including technical stops in the EU. General aviation, State flights, ferry and delivery flights and specialised operations are outside the scope.
Under ART.200 EASA completes the initial assessment within 30 days of receiving all required documents. The period is extended for any further assessment or audit, and it only starts when the application is complete.
TCO.300 requires the application at least 30 days before the intended start of operations. In practice operators should allow more time, because the clock only starts with a complete application.
Yes. Since 1 January 2026, Commission Implementing Regulation (EU) 2025/2347 sets an authorisation fee for new applications and an annual monitoring fee, plus charges for further assessments and on-site audits.
Changes affecting the authorisation, such as adding an aircraft type with a different ICAO type designator, moving the principal place of business to another State or a merger, need prior approval applied for at least 30 days in advance. Other changes must be notified before they take effect.
No. It is a safety authorisation. Operating permits and traffic rights are still issued by the Member States concerned.
Key takeaways
- Non-EU airlines need an EASA TCO authorisation for commercial flights into, within or out of the EU
- Apply at least 30 days before the first flight; EASA's 30-day assessment starts only with a complete application
- Part-TCO requires compliance with ICAO Annexes 1, 2, 6, 8, 18 and 19 and access for EASA inspectors
- EASA reviews authorised operators at least every 24 months, and changes need prior approval or notification
- Fees under Regulation (EU) 2025/2347 apply from 1 January 2026
Planning EU operations?
Tell us your fleet, AOC and planned EU routes. ASG will assess your TCO readiness and support you through the application and EASA assessment.