No one carries passengers or cargo for compensation under RBAC 135 (Brazil's equivalent of FAR Part 135) without first holding two documents: the Air Operator Certificate (COA) and the operations specifications (EO). 119.5(a)(1) of RBAC 119 is direct: the operator obtains both before starting operations.
This guide covers the road there. What RBAC 135 requires day to day is in the map of RBAC 135; what the EO contain, in operations specifications; and the criteria for the smaller category, in Simple Operator. Here the subject is the process: the phases, what is delivered in each one and how long ANAC indicates it takes.
The rule that governs the process is IS 119-004, revision M, approved by Regulatory Ordinance No. 5/SPO, of March 3, 2026.
Before applying: what needs to exist
Three decisions come before the first form, because they change the size of everything that follows.
The company. The service is operated by a legal entity. The service page on gov.br allows an individual to take part in the process only up to phase 3, provided they incorporate as a legal entity to continue.
The aircraft. ANAC Resolution No. 659/2022 makes operating the air service conditional on two things (art. 2): completing the certification process, when required, and being the operator of an aircraft in airworthy condition. The aircraft moves from the private registration category to the air taxi category, and the company must be listed as the operator in the Brazilian Aeronautical Registry. These two steps appear between steps 3 and 5 of the service on gov.br.
The category. IS 119-004 separates the Simple Operator from the Standard Operator (§4.1.14 and §4.1.15). An operator is Simple when it meets all the criteria at the same time: at most one aircraft, of a model with up to 9 passenger seats; up to 2 pilots in command and 3 seconds in command; exclusively non-scheduled and domestic operation, with no authorization for complex special operations and no maintenance privilege under the certificate. Anyone who fails any one criterion is Standard. The difference in the process is further below.
The people. 119.69(a) requires, for 135, five management positions: Director or Manager of Operations, Chief Pilot, Director or Manager of Maintenance, Director or Manager of Safety and Accountable Manager. The qualifications are in 119.71. The Simple Operator has a smaller structure (§6.4 of the IS).
The five phases of the process
IS 119-004 divides certification into five phases (§5.3.1.1): pre-application, formal application, document evaluation, demonstrations and inspections, and certification. The process is conducted by the Superintendence of Operational Standards, which gathers information and guides at gov.br/anac/voe135; official communications go through SEI.
Phase 1: pre-application
The company submits the Statement of Intent and takes part in the Pre-Application Orientation Meeting (ROP) with ANAC. This is where the operation's project is presented and the agency explains what lies ahead. The phase ends with a successful ROP.
The clock starts here: the Formal Application Package (PSF) must be filed within 30 days after the end of phase 1 (§5.3.5.1). The IS does not accept a request to extend this deadline, and missing it leads to compulsory closure of the process (§5.3.5.2). In practice, the manuals need to be well advanced before the ROP, not after.
Phase 2: formal application
This is the delivery of the package. The service page on gov.br lists what goes in it, with the reference rule for each document:
- Impact Analysis Form (FAI), from IS 119-004 itself;
- General Operations Manual (MGO), IS 135-002;
- Operational Training Program (PTO), IS 135-003, with the dangerous goods program (PTAP) recommended as part of it;
- General Maintenance Manual (MGM), IS 135.21-001;
- Safety Management Manual (MGSO) and Emergency Response Plan (PRE), RBAC 135 and IS 119-002;
- CRM Program Manual, Standard Operating Procedures (SOP) and Aircraft Operating Manual (AOM);
- Victim Assistance and Family Support Plan (PAVAAF), Program for the Prevention of Misuse of Psychoactive Substances (RBAC 120), Flight Data Monitoring and Analysis Program (PAADV) and Air Operator Security Program (PSOA).
Included as applicable: MEL, when operating with inoperative items; PTM, if the company performs its own maintenance; dangerous goods manual; manual for the transport of patients; flight attendant manual; and the programs required for aircraft with more than 9 passenger seats.
RBAC 119 adds the piece that ties everything together: the Initial Statement of Compliance (119.35), which goes through the sections of RBAC 91 and 135 with the means of compliance for each one. A manual that says one thing and a statement that says another is the most predictable finding of the next phase.
Phase 3: document evaluation
ANAC reviews the manuals and programs and returns findings. It is the longest phase in the gov.br reference, about 120 calendar days, and the one that depends most on the quality of what was delivered and on how quickly the responses come.
Phase 4: demonstrations and inspections
The operation leaves the paper and is seen working. gov.br lists the inspection of the main base, the airworthiness inspection, the operational evaluation flight and the en route check. Reference: about 60 days.
Phase 5: certification
Once the previous phases are complete, ANAC issues the COA and approves the operations specifications, and the process ends with the publication of an ordinance in the Official Gazette and the delivery of the documents. The gov.br page indicates in this phase the payment of the TFAC (code 011004) and asks for a copy of the company's articles of incorporation.
Operating the service begins only after the ordinance: that is what art. 2, § 1, of Resolution 659/2022 says, and the IS repeats that, once the COA and EO are issued, ANAC still verifies the other requirements of that resolution, such as the tax, social security and labor compliance of art. 3.
How long it takes
The service page on gov.br estimates up to 225 calendar days, adding up the averages of each phase: 15, 20, 120, 60 and 10 days. The page itself warns that the timeframe varies with the speed and accuracy of the applicant's responses.
And the IS makes clear that these numbers serve to plan the schedule, not to hold the agency to account: the reference timeframes published by ANAC do not constitute regulatory deadlines for the end of the process (§5.3.4.2.6.1). The deadlines the IS imposes are on the company's side, such as the 30 days to file the PSF.
What changes for the Simple Operator
Revision M brought deviations specific to the category (section 6 of the IS). The ones that weigh most on the process:
- Management personnel (§6.4): instead of the full structure of 119.69, the Simple Operator presents the accountable manager and the person responsible for operational control of the flights and for airworthiness. The accountable manager may hold these roles at the same time.
- Safety (§6.5): the category is exempt from establishing and maintaining the SMS (SGSO) of 135.29, from having a safety manager and from submitting an MGSO. Instead, the Statement of Compliance describes the processes of hazard identification, risk assessment and control, monitoring and safety promotion, under the final responsibility of the accountable manager. IS 119-002 serves as a reference.
- Training and manuals: the manual system is simplified, and the training program relies on curricula already approved for other certificate holders.
- Fee: the Simple Operator's TFAC is that of Group I; the Standard's, that of Group III (§5.2.5.3).
- Documents: under Table 1 of the IS (§5.2.6.11), the MGSO, the emergency response plan, the PAVAAF, the PTM and the MAP appear only for the Standard Operator. The Simple Operator's formal application package has its own minimum list (§6.7.6.4): schedule of events, proof of the aircraft, Statement of Compliance, registration of management personnel, MGO, PTO, MGM and SOP, and the compliance statements for IS 108-001 and 120-002.
The gov.br page is the same for both categories and still lists the MGSO among the common documents. For the Simple Operator, what the IS provides is what applies, and the ROP is the time to confirm with ANAC the minimum package for your case.
After the certificate
The COA does not end the relationship with the agency. A change or vacancy in management personnel must be reported to ANAC within 10 days (119.69(e)(3)); a new aircraft, new base or new authorization goes through an amendment to the EO; and the records that 135 requires start being checked in every inspection. The manuals and programs approved or accepted in the process keep getting revisions, each with its own review.
Where Alis fits in
Alis does not conduct the certification process, which belongs to the company and its technical manager. What the air taxi module does is organize what comes out of it and needs to stay up to date afterwards:
- each process document with its own record, the current revision and its status at ANAC (draft, under review, accepted or approved), because accepted and approved are not the same thing;
- SMS with reports, risk matrix, emergency response plan, inspections, change management and indicators;
- ANAC-accepted electronic logbook, maintenance tracking counted down with every flight and crew rostering with warnings of expired ratings and training.
The air taxi page shows the module and the plans, starting with Simple, sized for one aircraft.
Regulatory sources
- IS 119-004, revision M, approved by Regulatory Ordinance No. 5/SPO, of March 3, 2026: §4.1.14 and §4.1.15 (categories), §5.2.5.3 (TFAC), §5.3.1.1 (phases), §5.3.4.2.6.1 (reference timeframes), §5.3.5 (PSF), section 6 (Simple Operator)
- RBAC 119, Amendment No. 10: 119.5, 119.35, 119.69 and 119.71
- RBAC 135, Amendment No. 15: 135.29
- ANAC Resolution No. 659, of February 2, 2022: arts. 2 and 3
- Service page "Certificar-se para explorar serviços aéreos públicos de acordo com o RBAC 135" (Get certified to operate public air services under RBAC 135), gov.br, updated on 10/01/2026
This article was written based on IS 119-004 revision M, RBAC 119 (Amendment No. 10) and 135 (Amendment No. 15), ANAC Resolution No. 659/2022 and ANAC's service page on gov.br, as published and read in November 2026. Timeframes and amounts indicated by ANAC may change. The text does not replace consulting the regulations or the guidance of ANAC and of the company's technical and operational manager.