Operations Specifications (EO) under RBAC 135

The Air Operator Certificate says who may provide the service. The Operations Specifications say what that company may do, with which aircraft, where and under which limitations. The EO is what answers whether that airplane may fly IFR with a single pilot, whether the company may carry dangerous goods and whether the fleet's logbook may be electronic.

What follows comes from RBAC 119 (Amendment 10), RBAC 135 (Brazil's equivalent of FAR Part 135, Amendment 15) and the EO model ANAC publishes today. For the overall picture of certification, see the RBAC 135 guide for air taxi.

COA and EO: two documents, one authorization

RBAC 119, in section 119.5(a)(1), requires the operator to obtain "a COA and the respective operations specifications (EO)" before starting operations. The same section closes both doors: conducting air transport without a COA and EO is prohibited (119.5(c)(1)), and a COA holder is prohibited from operating contrary to its EO (119.5(c)(2)).

Section 119.7 defines the role of each. The EO contain the authorizations, limitations and procedures under which each operation must be conducted, and the procedures for each class and size of aircraft. Paragraph 119.7(b) clarifies the relationship: except for the paragraphs identifying the authorized kinds of operation, the EO are linked to the COA but are not part of it.

Under section 119.21(a), airplanes with up to 19 seats and 3,400 kg of payload, and helicopters, operate under RBAC 135 and must hold EO issued in accordance with those requirements.

What RBAC 119 requires them to contain

For a non-scheduled operator under RBAC 135, the minimum content is in section 119.49(c). In short, the EO carry:

the address of the headquarters and other authorized trade names;
the authorized kinds and areas of operation;
type, nationality and registration marks and serial number of each authorized aircraft;
maintenance data: registrations under an inspection program (135.419), time limits for overhauls and inspections of aircraft under a continuous airworthiness maintenance program, and additional items required by ANAC (135.421);
wet leasing information (119.53(c));
authorizations for deviations or exemptions from RBAC requirements;
the authorization or prohibition to carry dangerous goods;
the authorization of the weight and balance control method, when required;
any other item ANAC deems necessary.

For the aircraft item, the list may be incorporated by reference to a document kept up to date, subject to ANAC approval of form and content (119.49(c)(6)(i)). And the next line is blunt: the certificate holder "may not conduct operations using an aircraft not listed" (119.49(c)(6)(ii)).

What the EO looks like today

ANAC publishes on gov.br the EO of each certificated air taxi operator, with the COA number and the link to the document in SEI.

In the published EO we reviewed, the document is bilingual and follows the same structure:

Part A, general information: ANAC contact, corporate name and COA, authorized kinds of operation (scheduled or non-scheduled, domestic or international), addresses of the headquarters and of the main operations and maintenance bases, and the required management personnel, by name and position.
Part B, operations and limitations: operator authorizations (such as dangerous goods), authorizations per aircraft model (EFB, PBN, RVSM, uninhabited terrain, passengers or cargo, single-pilot IFR), ETOPS, other authorizations or exemptions, and leasing or interchange.
Part C: aerodromes and authorized maintenance, the latter according to the List of Maintenance Bases accepted or approved by ANAC.
Part D: acronyms and the revision control, where each revision shows the date, a summary of the change and the ANAC process number.

The standard text of Part B states that the authorizations remain valid for the duration of the COA, unless ANAC suspends or revokes them, or they need to be updated because of changes in the operation. It also states that the operator must carry a copy of the EO on board the authorized aircraft. The table of other authorizations or exemptions has a validity column: in one of the EO we reviewed, a temporary and partial exemption from an RBAC 135 requirement, granted for a single registration, had its end date written there.

Specific authorizations that live in the EO

Many of the authorizations RBAC 135 makes conditional go through the EO. Some examples from the text:

Autopilot in place of the second in command. Section 135.105 allows operating without a second in command with an approved autopilot, provided its use is authorized by the EO. The operator requests an amendment to the EO (135.105(c)), and the amendment may contain conditions and limitations (135.105(e)).
Dangerous goods as cargo. Under section 135.505(a), this requires prior ANAC authorization in the Operations Specifications.
MEL. Section 135.179 requires an ANAC letter authorizing operations under the approved MEL, and the aircraft must be operated under the conditions of the MEL and of the EO authorizing its use.
Inspection program. Under section 135.419, ANAC may amend the EO to require or allow an inspection program, and an operator requesting that change attaches the program to the application.

The electronic logbook

Portaria nº 3.220/SPO/SAR, of October 15, 2019, which sets the reference model for the eDB, defines where the authorization is recorded. Under art. 48, it is issued in the operator's name and recorded in the EO, for aircraft listed in the EO of operators certificated under RBAC 119, or in a LOA, for all other aircraft. An authorization by EO covers every aircraft whose registration appears in it (art. 48, § 1).

This has consequences for fleet management. An aircraft added to an EO that already holds the authorization has up to 30 days to migrate to the eDB (art. 49, § 2). An aircraft removed from the EO requires an immediate LOA for the registration no longer covered, with no return to the paper logbook by the same operator (art. 49, § 3). The same Portaria, in art. 10, § 1, allows the eDB to be filled in during non-critical phases of flight by an operator certificated under RBAC 119 that holds an EFB authorization in its EO.

ANAC's electronic logbook page describes the RBAC 135 process as an EO change for the use of digital records, with forms FOP 219, D-144-01 and FAI, and the revised manuals filed in a separate process. The fee shown is R$ 3.000,00. According to the list of already verified software, the first authorization to use each system requires an operational evaluation, carried out jointly by the developer and the operator. In the published EO, the authorization appears in the table of other authorizations as "Autorização de uso de Diário de Bordo Eletrônico (eDB)", with its applicability (for example, the whole fleet) and the identification of the system. For the process on the operator's side, see the article on the electronic logbook and ANAC.

Who can change it, and when the amendment takes effect

Section 119.51 provides two paths to amend the EO:

On ANAC's initiative, when it determines that air transport safety and the public interest require the amendment. In this case, the amendment takes effect no less than 30 days after the holder is notified, unless there is a safety emergency requiring immediate action, in which case ANAC notifies the holder and explains its reasons (119.51(b)).
At the certificate holder's request, when ANAC finds that safety and the public interest allow the amendment. This amendment becomes effective on the date of issue (119.51(c)).

The operator does not edit the EO: it applies, and ANAC issues. A wet leasing contract, for example, results in an amendment to the EO of both parties (119.53(c)). In the revision control of the published EO, a change of director of operations, chief pilot or accountable executive, the addition of an aircraft model and the addition of an EFB or eDB authorization all appear as revisions.

Validity has its own rule. Under section 119.61, the EO cease to be effective, among other cases, when the holder stops conducting a kind of operation beyond the period in section 119.63: 90 consecutive days for non-scheduled operations. After that, resuming requires notifying ANAC at least 15 days in advance and being available for a possible inspection. A change of address of the headquarters or main bases requires written notice to ANAC at least 90 days in advance (119.47(b)).

Why the manager needs to keep the EO checked against the operation

The EO is the legal boundary of the operation, and RBAC 119 requires the holder to make it circulate. Section 119.43 requires a complete set of the EO kept separately at the headquarters; extracts or references in the manual of section 135.21, identified as parts of the EO and stating that compliance is mandatory; every employee informed of the provisions that apply to their duties; and a copy of the EO on the aircraft, with an English translation on those authorized for international operations.

RBAC 135 repeats the link from the manual side: the general operations manual may not contradict the COA or the EO (135.21(d)) and must include copies of the EO or information extracted from them (135.23(a)(3)). Section 135.63 requires keeping the EO and an up-to-date list of the aircraft and the operations each one is equipped for. And section 119.59(e) states that failure to promptly make the certificate, the EO or a required record available is grounds for total or partial suspension of the certificate and the EO.

Divergence usually starts with a legitimate change that never reached the EO, or with a revised EO that never reached the manual and the aircraft. A check at every change in the operation covers the essentials:

every aircraft in use is listed, with the correct registration and serial number;
the management personnel in Part A are the people actually in those positions;
headquarters and base addresses match reality;
each kind of operation flown (passengers, cargo, single-pilot IFR, uninhabited terrain, aeromedical, offshore) is authorized for the right model;
exemptions with a validity date are still within it;
the eDB authorization covers every registration using the electronic logbook;
the copy on board and the manual extracts are at the current revision.

The EO is one of the process documents for both operator categories (see the Simple Operator), and the maintenance limitations it carries are part of what changes in maintenance tracking (see RBAC 91 vs. 135 in the CTM).

Where Alis comes in

In the air taxi module, the ANAC documents tab of the SMS (SGSO) lists the eight documents of the ANAC process, among them the Operations Specifications. For each one, the manager records the current revision and its date, the status with ANAC (draft, under review, accepted or approved), the process number and the date of acceptance or approval, and links the record to the file already in the Library. The list comes out in full, including what was never registered, and flags open items such as a document with no revision informed, no file, or accepted with no date.

The Alis electronic logbook is a system accepted by ANAC: Alis Aviation is on the list of software whose IT compliance has already been verified by the Agency. Authorization to use it in your fleet still comes through the EO, and after that the system warns of the operator's signature deadline, which is 15 days under RBAC 135.

Want to see the ANAC documents and the eDB at work? Book a demo.

This article is for information only. It draws on RBAC nº 119, Amendment 10 (in force since November 1, 2024), RBAC nº 135, Amendment 15 (in force since January 9, 2026), Portaria nº 3.220/SPO/SAR, of October 15, 2019, in the text consolidated up to Portaria nº 15.103/SPO, of July 24, 2024, and ANAC's pages on RBAC 135 operations specifications and on the electronic logbook, as they stood in October 2026. It does not replace reading the regulations, your operator's EO, or the guidance of the person responsible for maintenance or operations.