Getting a CIAC training program approved by ANAC

Schools that look for consulting to get a training program approved by ANAC (Brazil's civil aviation authority) are usually in one of two situations: the school is adding a new course, or it wants to replace the old program with one structured around competencies. In both cases the question is the same: what ANAC reviews, where the request is filed and how much of the work is writing.

A vocabulary adjustment helps when reading the rules. The Brazilian market says "homologar". RBAC 141 (the Brazilian regulation for civil aviation training centers, the CIAC) speaks of an approved training program (PI) and an accepted MIP (instructions and procedures manual). They are different acts, with different effects, and this article uses the terms of the regulation.

What ANAC requires of a training program

The obligation is in section 141.23 of RBAC 141: the CIAC must have a training program approved by ANAC for each course it teaches that is provided for in RBAC 61, 63 or 65. Paragraph (b) lists the minimum content:

the course curriculum, with content, hours and the learning experiences of each class, lesson or activity;
the aircraft and training equipment used;
the procedures to monitor and assess student performance and the minimum passing criteria;
the bibliography;
the maximum duration of training activities per period.

IS 141-007D details how to comply. Item 1.1 defines the PI as the document in which the CIAC describes the purpose, objectives, methods, materials, sequence and standardization of the activities, and warns that, once approved, it must be followed in full. Item 1.5 asks that the program start from competencies: the IS sets final competencies for each license, and the CIAC must, at a minimum, reach them. The question the IS itself suggests is "what should the student be able to do?", in place of "what content should the student learn?".

In the Private Pilot chapter, the questions and answers make the expected level of detail clear. It is not enough to list competency units and leave the progression to the instructor's discretion: the program has to be standardized, trackable and traceable. And each training activity has its own form, with the objectives and the elements assessed. The item-by-item summary of the IS is in the article on IS 141-007D.

CBTA: what it is and why it is optional

CBTA (Competency-Based Training and Assessment) is the methodology of ICAO's PANS-TRG (Doc 9868) in which the unit of training is the competency, described by observable behaviors. How it works is explained in the article CBTA and EBT up close. The distinction matters: EBT is airline recurrent training; in initial training, the subject is CBTA.

ANAC published the CBTA Guides for CIACs that want to develop their curricula with this methodology: a guidelines guide and specific guides, among them the one on Private Pilot training. The guidelines guide is direct about whether it is mandatory: use of the methodology is not mandatory, it is optional for the development of the CIAC's training programs. The Guides also do not replace RBAC 141 or IS 141-007D.

For those who opt in, there are rules. The Private Pilot training Guide says that CIACs adopting the model must follow the competency matrix, the curricula and the guidance in the Guide for the approval of their PIs. Among the points it brings:

the adapted matrix for Private Pilot has nine competencies, each with its observable behaviors (OB);
the practical course remains divided into phases and missions, as in chapters 7.1 and 8.1 of IS 141-007D, and the Guide expects each OB to be observed and recorded around four to five times over the missions;
the training forms change in form and content to record competencies and OBs;
an additional theoretical curriculum comes in, to be taught before the practical one, and the use of an AATD in the practical curriculum becomes mandatory;
the school defines the roles of instructor and assessor and writes the Instructor Manual, the subject of a guide of its own.

In other words: CBTA is a choice, and a choice that demands structure.

The approval path: SEI, the Training Program and the MIP

The process belongs to the school and runs through ANAC's SEI Electronic Protocol. IS 141-004A describes the package for approving a training program: forms FOP 400, FOP 402 (course coordinator), FOP 406 and FOP 407, which forwards the program, the impact analysis form (FAI), the attachments on aircraft, FSTDs, facilities and resources and, after the document review, FOP 413 for the inspections and demonstrations. The approved program receives a FOP 411; the accepted manual, a FOP 412.

Three points of IS 141-007D tend to be underestimated:

Statement of compliance (item 1.10). The CIAC indicates in which item and page of the PI it met each provision. Without it, ANAC does not start the review.
Run it only after approval. A program that has only been filed cannot be advertised, have enrollment opened or have a waiting list (item 1.20.1).
The PI and the MIP follow different regimes. An amendment to the PI depends on prior approval (141.23(e)). An amendment to the MIP is sent to ANAC at least ten calendar days before it takes effect and does not depend on prior approval (141.25(e)). A CBTA PI touches both: the program itself, and in the MIP the records, the forms and student monitoring.

The IS also provides, in item 1.8, for the pre-approved program: a complete package offered by the market, which went through pre-approval at ANAC and which the CIAC adopts by means of an adoption and customization form. It is a path with its own rules, different from buying content and submitting it as the school's program.

The review is ANAC's. No supplier can promise its outcome or its timing.

What takes work

Filing is the short part. What takes up the coordination team's time is what comes before:

Structuring the missions: phases, sequence, objectives of each flight, maneuvers of each mission, one form per activity;
Tying competencies to criteria: which behaviors are observed in which mission, against which criterion, and how many times over the course;
Writing the documentation: the program, the item-by-item statement of compliance, the changes to the MIP, the instructor manual;
Making the records follow the program: if the form the instructor fills in is not the form of the approved program, what was approved and what is carried out drift apart, and that is what an inspection finds.

It is also the part for which consulting is usually hired, and the one that has to be redone for each new course.

How a ready-made program shortens this part

The Alis Training Program is a CBTA-based training program that goes straight into the school's system. The school contracts the program as an add-on to the flight schools module, for R$ 390 per month, Alis enables it, and the content appears already built: courses, phases, missions, maneuvers, competencies and assessment criteria, with the program manual. Competency assessment is done on the FIP of each mission, so that the record and the program are the same thing.

The program is sold complete, not per course: the add-on unlocks seven courses at once. Private Pilot (39 missions, 42.3 h, of which 2.6 h in an AATD simulator), Commercial Pilot (65 missions, 113 course hours, of which 7.5 h in an AATD simulator, adding up to 150.2 total hours with the Private Pilot hours), Instrument Flight (31 missions, 50 h, of which 30 h in an AATD simulator) and Flight Instructor (31 missions, 31 h, of which 3 h in an AATD simulator) are courses that depend on an approved program. There are also two integrated courses, which start from the Private Pilot license: Commercial Pilot with IFR (84 missions, 144.8 h) and Commercial Pilot with IFR and Multi-Engine (93 missions, 151.8 h). Compared with taking Commercial Pilot and IFR separately, the integrated course saves about 10.7 h of airplane time and 7.5 h of simulator time. Multi-Engine (13 missions, 12 h) comes in differently: under item 7.10 of IS 141-007D, a course aimed only at the multi-engine class rating does not require ANAC approval, so it arrives as reference content.

Each course has its own manual, organized in the structure of ANAC's CBTA Guides, with the competency matrix, the observable behaviors and the assessment plan. Each course also carries its hours table against the minimums of RBAC 61 and IS 141-007D, and each mission lists the focus maneuvers and the routine ones of the flight, so the form assesses the whole flight. The adopted content is not editable by the school; it can add missions of its own.

Schools that adopt the program display the Competency-Based Training & Assessment Center seal. It is an Alis Aviation seal, which identifies use of the program; it is not a certification from ANAC, ICAO or IATA.

What it does not do needs to be equally clear. The approval belongs to the school. The CIAC opens the process in SEI, incorporates the content into its Training Program and its MIP and responds to ANAC's review. Alis delivers the content and the documentation of the program, not the approval, and does not promise an outcome or a deadline. The gain is in not starting from a blank page: the structure of missions, competencies and criteria, which is the most time-consuming part, arrives ready and is already the one the instructor uses day to day.

Want to see the seven courses inside the system? Book a demo.

This article is for information purposes and does not replace consulting the regulations or the guidance of the course coordinator. Sources: RBAC 141, Amendment 03, sections 141.23 and 141.25; IS 141-007, Revision D (Portaria nº 13.686/SPL, of January 24, 2024), items 1.1, 1.5, 1.8, 1.10, 1.20.1, 7.10 and chapter 7.1; IS 141-004, Revision A, items 4.1.21, 5.1.2.8, 5.1.5.1, 5.1.7 and 5.2.10.4; ANAC's CBTA Guides (SPL): Diretrizes de Formação e Avaliação Baseadas em Competências, July 2026 edition, and Formação do Piloto Privado, August 2025 edition; ICAO Doc 9868 (PANS-TRG). Always check the current revision of each document.