Permit Coordination Challenges for Multi-Operator Flights

Obtaining international overflight and landing permits is a requirement for any flight that crosses another country’s airspace or lands within its territory. These permits are issued by the respective civil aviation authority, which reviews factors such as airworthiness compliance, regulatory adherence, and airport slot coordination. In multi-operator flights, coordinating these permits across all involved carriers is essential to ensure smooth operations and regulatory compliance.

Understanding Flight Permit Procedures

Airlines and charter operators are required to submit detailed applications in advance, providing information such as aircraft specifications, planned routes, and crew details. Processing times vary considerably. In some states, permits may be issued within 1–5 business days, while others, such as Mongolia or Togo, may require one to two weeks.

 

Certain exceptions apply; for medical or other urgent operations, approvals may be granted within 24 hours or less. The responsibility for obtaining permits lies with the operator of record, typically the airline or charter company holding the Air Operator Certificate (AOC). Even in cases of wet leasing or codeshare agreements, the permits must be filed under the name of the actual operating carrier.

 

Permit issuance generally involves associated costs, including overflight and landing fees. Coordination with air traffic control and airport slot management is also essential. In practice, permits and slots must be secured together; obtaining one without the other may still prevent the flight from operating as scheduled.

Multi-Operator Flight Arrangements

Certain flights may involve more than one airline through codeshare agreements or ACMI (Aircraft, Crew, Maintenance, and Insurance) wet-lease arrangements. In a codeshare, the setup is primarily commercial: one airline operates the flight, while one or more partners market it under their own flight numbers. For example, Airline A may operate a Seattle–Frankfurt service, but Airlines B and C can also sell seats on the same flight as their own.

 

ACMI or wet leasing is operational in nature. The lessor airline provides the aircraft, crew, maintenance, and insurance, while the lessee covers fuel, ground services, and other variable costs. The flight operates under the lessor’s Air Operator Certificate (AOC), with its crew in command, but on behalf of the lessee airline.

 

In both cases, the operating carrier (the holder of the AOC) retains full operational control and is responsible for securing permits. Codesharing or leasing does not shift permit obligations to the marketing or lessee airline. These arrangements require clear contractual terms. The operating carrier files the necessary applications, while partner airlines coordinate schedules and share operational data. In ACMI or wet-lease agreements, industry practice requires both parties to confirm that all certificates and permits are in place before the service begins.

 

In practice, the lessor submits permit applications under its own name, while the lessee typically provides routing information and covers the associated fees. Similarly, codeshare partners must ensure their joint operations remain consistent with bilateral air service agreements, even though only the operating carrier files the permits.

 

Effective coordination is essential because multiple parties are involved. The operator manages the permit process, including detailed flight plans, crew licenses, and insurance documentation. Marketing carriers synchronize schedules and ticketing with the confirmed plan, while ground handling and slot coordination teams must also be aligned. In many jurisdictions, landing permits require confirmation of an allocated airport slot. Any breakdown in communication between airlines or support providers can result in delays or denied approvals.

Who Applies for Permits?

Regulations generally require that overflight and landing permits be requested by the operator of record. For example, Brazil’s civil aviation authority specifies that overflight notices must be registered in the name of the airline or entity operating the flight. This principle applies in most jurisdictions: the Air Operator Certificate (AOC) holder files the application. Even when a flight is marketed entirely by another carrier, only the actual operator may submit the permit request.

 

In a codeshare arrangement, if Airline A operates a flight marketed by Airline B, the application is submitted under Airline A’s AOC. Airline B relies on Airline A’s permit confirmation when selling tickets. When several airlines codeshare on one service, only one permit application is filed by the operating carrier. Each marketing carrier must still hold the required traffic rights under the relevant bilateral agreement to sell seats. This is a separate regulatory requirement.

 

In ACMI or wet-lease operations, the lessor provides the aircraft, crew, maintenance, and insurance. Regulators treat the lessor as the operator, so the lessor files the permits. The lessee defines the routing and pays the charges, but the documentation remains with the lessor. In a dry-lease arrangement, the lessee operates the aircraft under its own AOC and is responsible for filing permit applications.

 

Airline operations manuals and leasing contracts typically specify permit responsibilities. However, confusion can still arise in complex scheduling scenarios. For instance, if a marketing carrier books a new codeshare route without confirming that the operating partner holds the required permits, last-minute issues may occur. Similarly, if a wet-lease carrier changes the operating AOC mid-season, flight teams must update all permit filings under the new operator.

Common Coordination Challenges

Flight operators face several challenges when multi-operator flights require permits:

Complex Scheduling and Communication

Permit processing involves many stakeholders, including airlines, agents, and authorities. A schedule change by one partner, such as a timing update by a marketing carrier, may require reapplying for airport slots and updating permits. Poor communication in this process can lead to expired or invalid authorizations.

Tight Lead Times

Last-minute route adjustments or diversions place additional strain on the permit process. In some regions, landing permits for non-scheduled flights may require 20–30 days of lead time, while routine overflight permits often take 3–5 business days. Delayed coordination can cause significant setbacks; in one reported case, an airline waited more than a year to obtain a new Kathmandu–Delhi landing permit.

Regulatory Differences

Permit requirements vary across jurisdictions. Certain authorities request additional documentation for charter or ACMI flights, such as maintenance records or political clearances. If a codeshare partner is based in a country with stricter requirements, the operating carrier must comply with those rules in addition to the standard process.

Slot and Permit Misalignment

At congested airports, landing slots and permits are often obtained through separate processes. Operators must ensure the approved slot time aligns with the authorized permit. In some cases, an airline may secure a slot but lack a corresponding landing permit, resulting in operational delays and additional costs.

Multiple Marketing Carriers

When multiple airlines market the same service, documentation complexities can arise. Air Waybills, passenger manifests, or accounting references may need to reflect different codes for each carrier. Clear procedures are required to determine which airline’s identifiers appear on official flight plans and permit applications.

Last-Minute Changes

Diversions or unplanned technical stops en route necessitate immediate permit requests. In multi-operator flights, the operating carrier must quickly file the application, while partner airlines are responsible for notifying ground service providers. Coordinating such changes in real time presents significant operational challenges.

Understanding Permit Coordination in Action

The following examples demonstrate how permit responsibilities and challenges emerge across different multi-operator flight configurations, providing operators with insight to anticipate and manage real-world complexities:

Scenario 1: ACMI/Wet-Lease Flight

A European charter airline (Operator X) wet-leases an Airbus A320 with crew to a Middle Eastern carrier (Lessee Y) to operate additional summer flights. Lessee Y markets the service under its brand, while the flight is operated under Operator X’s AOC and crew. One example route runs from Cairo to Paris, transiting Greek and Turkish airspace.

 

• Permit Responsibility: Operator X, as the AOC holder, files the overflight permits with Egypt, Greece, and Turkey, as well as the landing permit for France. Although Lessee Y sells the tickets, the permits are issued in Operator X’s name. The flight plan is also filed using Operator X’s call sign.

 

• Coordination: Lessee Y provides the itinerary and covers navigation and landing charges, while Operator X’s operations control office manages the permit submissions. Operator X ensures valid airworthiness documentation and crew licensing for regulatory approval. Lessee Y, meanwhile, must confirm that its traffic rights allow ticket sales on the Cairo–Paris sector in accordance with bilateral agreements.

 

• Challenge: If Lessee Y lacks liberalized traffic rights with France, marketing seats on the Cairo–Paris route may require separate authorization from French authorities. While this is a commercial rights issue rather than a technical permit requirement, both processes must proceed in parallel. Any delay in obtaining commercial approval could prevent issuance of the landing permit, illustrating how traffic rights and permit procedures can intersect.

 

• Wet-Lease Role Definition: Operational control remains with Operator X. Its AOC dictates that the crew follow Operator X’s operating procedures, and the lease agreement specifies responsibility for safety and permits. While Lessee Y may participate in passenger-facing tasks, all regulatory matters are addressed by Operator X.

 

• Data Point: The ACMI leasing sector is expanding. Industry data valued the global ACMI market at approximately USD 5.24 billion in 2023, with projected annual growth of around 5.7%. This trend highlights the increasing prevalence of wet-lease arrangements and the importance of precise permit coordination between partners.

Scenario 2: Complex Multi-Segment Flight

A charter operation involves a multi-leg journey with different carriers. A business charter departs New York for Nairobi with an intermediate stop in London (Luton). The first leg is flown by an American airline (Operator A) on a Boeing 787, while the onward London–Nairobi segment is operated by an African carrier (Operator B) using a smaller aircraft. Operator B is authorized to serve Nairobi but does not operate transatlantic flights.

 

• Permit Responsibility: Operator A applies for overflight permits across the North Atlantic, Canada, Greenland, and Europe, along with the landing permit for London. Operator B files for its own overflight permits over European airspace and a landing permit for Nairobi. Each carrier is responsible for the permits tied to its own flight segment.

 

• Coordination: The charter broker coordinates the overall trip, but each operator works under its own AOC. At London, aircraft and crew change, making the journey a continuous booking for passengers but separate flights in regulatory terms. Operator A’s permits expire upon arrival in London, while Operator B’s permits apply from London to Nairobi.

 

• Challenge: The handover requires precise timing. Operator A must secure a landing permit in London that exactly matches its arrival window, while Operator B must hold a valid departure clearance from London. Any delay in the first leg could force adjustments to Operator B’s permit or require rescheduling of its departure slot. Poor coordination risks operational disruption and passenger inconvenience.

 

• Multi-Operator Gateways: Although relatively uncommon, such split operations emphasize that no single permit covers an entire multi-segment charter. Each operator must hold permits for its respective leg. Ground handlers at transfer points, such as London, play a critical role by aligning both permit sets and ensuring crews coordinate seamlessly during the transition.

FAQs on Permit Coordination Challenges for Multi-Operator Flights

1. Can a marketing carrier be held liable if the operating carrier fails to obtain a permit?

Regulatory responsibility rests with the operator of record. This is the airline listed as the operating carrier on the flight plan and holding the AOC. However, marketing carriers may still face commercial repercussions if a flight is delayed or denied entry due to a missing permit, particularly in charter or ad-hoc operations. Partner contracts often include indemnity clauses, which can assign financial responsibility depending on the circumstances. Thus, while legal liability lies with the operator, commercial risk may affect both parties if permit responsibilities are not clearly defined in advance.

2. What are some common documentation issues that cause permit denials in multi-operator flights?

Permit applications can be rejected due to incomplete or inconsistent documentation. In multi-operator operations, frequent issues include:

 

• AOC copies that do not match the aircraft registration on the flight plan
• Insurance certificates that fail to cover the full route, including overflight segments
• Crew license discrepancies, such as mismatched nationality or expired qualifications
• Conflicts between flight plan call signs and the operator’s official documentation
• Wet-lease agreements that do not clearly define operational control

 

Authorities may delay or deny permits if there is uncertainty regarding the operating carrier or if the paperwork does not comply with local regulatory requirements.

3. How do permit requirements differ for ferry flights under ACMI leases?

Ferry flights, or non-revenue positioning flights, under ACMI arrangements may still require full overflight and landing permits, depending on the jurisdiction. Some states exempt ferry flights from commercial traffic rights requirements because no passengers or cargo are carried. Operators must provide:

 

• Aircraft registration and airworthiness certificates
• The ACMI contract demonstrating legal responsibility and the purpose of the flight
• Documentation confirming the non-commercial nature of the operation

 

Misclassifying a ferry flight (for example, marking it as “charter”) can lead to unnecessary delays or regulatory scrutiny. Certain jurisdictions may also require a temporary import permit if the aircraft remains on the ground for an extended period.

4. Are there specific aircraft types that face more scrutiny for permit applications in multi-operator use?

Yes. Older aircraft models or those registered in less common jurisdictions often undergo additional review. In multi-operator operations, scrutiny may increase if:

 

• The aircraft has recent changes in registration or ownership
• The model has limited operational history in the overflown region
• The application involves variants with special noise or emissions classifications

 

Non-standard configurations, such as medevac setups or quick-change interiors, may also require supplementary airworthiness documentation, particularly for ad-hoc wet-leases or urgent ACMI flights.

5. How do joint flight operations affect flight plan filing and ATC handling?

In multi-operator flights, only the operating carrier files a flight plan with air traffic control. The flight plan includes:

 

• The operating airline’s call sign
• The aircraft registration associated with its AOC
• Contact details for dispatch and flight operations

 

Marketing carriers in codeshare or ACMI arrangements do not submit separate flight plans. However, they must ensure that published schedules and reservation systems match the field plan to prevent conflicts or passenger confusion.

Best Practices for Permit Coordination

Effective permit management for multi-operator flights requires proactive planning and communication:

 

• Clarify Roles Early: Define the operating carrier for each leg and assign permit responsibilities before finalizing bookings. Ensure alignment with marketing and codeshare arrangements.
• Apply Early: Submit permit applications well in advance, especially for congested airports or charter flights, to allow sufficient lead time.
• Maintain Clear Documentation: Share approved flight plans and permit confirmations with all partners and update jointly if schedules change.
• Coordinate Costs: Specify in contracts who is responsible for navigation and landing fees and ensure timely payment to avoid delays in permit issuance.
• Monitor Permits: Keep a checklist of active permits for each flight, noting expirations or amendments required due to diversions or delays.
• Flight Support Service: Effective coordination is critical in multi-operator flights to ensure permits and operations run smoothly. Just Aviation provides expert support in managing permit submissions, ground handling, and inter-operator communication. Our team addresses key requirements, including diplomatic clearances and insurance conditions, helping operators maintain full compliance and avoid operational delays.

 

By clearly defining responsibilities and maintaining organized coordination, multi-operator flights can navigate the complex framework of international overflight and landing permits efficiently. Operators can ensure that every aircraft and crew involved in joint flights are fully authorized for each segment, minimizing operational risk, delays, and helping avoid hidden operational costs.