Starting an air taxi has always had the same problem: the obligations of holders of an Air Operator Certificate (COA) were written with companies of dozens of aircraft in mind, and they landed in full on someone with one.
That has changed. ANAC created the Simple Operator category — and it redraws the size of the bill for the small operator, from the annual fee to the level of complexity expected in the manuals.
This article explains what the category is, who qualifies and what is still required of everyone.
Simple Operator: the category almost nobody has explained yet
IS 119-004, revision M, approved by Regulatory Ordinance No. 5/SPO, of March 3, 2026, created in §4.1.14 the distinction between Simple Operator and Standard Operator.
Classification is not a choice — it follows from the profile of the operation. To be Simple you must meet all the criteria at the same time:
| Criterion | Simple Operator limit |
|---|---|
| Fleet | at most 1 aircraft |
| Aircraft configuration | model with a maximum certified configuration of up to 9 passenger seats |
| Crew members | up to 2 PIC and 3 SIC |
| Nature of the operation | exclusively non-scheduled and domestic |
| Complex special operations | no authorization |
| Maintenance under the certificate | no privilege |
Missing one criterion is enough to be a Standard Operator. There is no middle ground, and the operator does not get to choose.
Why it matters to your wallet
The most direct difference is in the TFAC: under §5.2.5.3, the Simple Operator falls in Group I, and the Standard in Group III. For someone operating a single aircraft, landing in the wrong group over a classification detail is expensive.
And there is a difference that does not show up in a table: the IS does not shorten the Simple Operator's list of documents — it reduces their expected complexity. The MGO of an operator with one aircraft and two captains does not need to be the size of the MGO of a company with a fleet. It is still required; it need not be bloated.
The eight documents ANAC requires
Under §5.2.6, the list applies to both categories — Simple and Standard. What changes is the depth, not the set:
- MGO — General Operations Manual
- MGM / PMAC — maintenance and the aircraft maintenance program
- MGSO — Safety Management Manual
- PTO — Operational Training Program
- PTM — Maintenance Training Program
- MAP — when applicable
- FAI
- EO — Operations Specifications
In Alis, these eight each have their own record: current revision, status with ANAC (draft, under review, accepted, approved), case number, decision date and link to the Library. Accepted and approved are deliberately different states — treating them as synonyms is the kind of imprecision that shows up in an audit.
SMS (SGSO): required from day one
Anyone holding a COA needs an SMS (SGSO). IS 119-002D is the development guide, and it organizes the system into four pillars:
- Policies and objectives — formal commitment, responsibilities, designated manager
- Risk management — hazard identification, analysis, mitigation
- Safety assurance — performance monitoring, management of change, continuous improvement
- Promotion — training and communication
One detail worth knowing: IS 119-002D dates from 2012. It does not know the Simple Operator category — it was written when every COA holder was treated the same. In practice, it is up to the operator to size the SMS to the scale of the operation without failing to meet the four pillars.
The PTM has its own, more recent rule — IS 119-010A, of August 7, 2025 — which structures initial indoctrination, initial technical, specialized, recurrent and corrective training, with records kept for five years after termination. The PMAC follows IS 120-016D, of January 7, 2026.
Frequently asked questions
Who qualifies as a Simple Operator?
Under IS 119-004 rev. M, §4.1.14, you must meet all the criteria at the same time: at most 1 aircraft, of a model with a maximum certified configuration of up to 9 passenger seats; up to 2 PIC and 3 SIC; exclusively non-scheduled and domestic operation; no authorization for complex special operations; and no maintenance privilege under the certificate. Anyone who fails to meet any one of them is a Standard Operator.
Does the Simple Operator need fewer documents?
No. Under §5.2.6 the list of eight documents — MGO, MGM/PMAC, MGSO, PTO, PTM, MAP when applicable, FAI and EO — applies to both categories. What the IS recognizes is that the expected complexity of those documents follows the scale of the operation.
What is the TFAC difference between Simple and Standard?
Under §5.2.5.3, the Simple Operator falls in Group I and the Standard Operator in Group III. It is the most direct difference between the two categories.
Does an air taxi need an SMS (SGSO)?
Yes. The SMS (SGSO) is a requirement for anyone holding a COA, and IS 119-002D is the development guide, with the four classic pillars. Note that this IS dates from 2012 and does not include the Simple Operator category — sizing the system to the scale of the operation, without failing to meet the pillars, is the operator's responsibility.
Can I use an electronic logbook in an air taxi operation?
Yes, and the path is the same as for any operation: an ANAC-accepted system and authorization of your operation. For an operator certificated under RBAC 119, the authorization is recorded in the Operations Specifications. See the page on the eDB.
Regulatory sources
- IS 119-004, revision M — approved by Regulatory Ordinance No. 5/SPO, of March 3, 2026; §4.1.14 (Simple and Standard Operator), §5.2.5.3 (TFAC), §5.2.6 (required documents)
- IS 119-002D — SMS (SGSO) development guide for certificate holders under RBAC 119
- IS 119-010A, of August 7, 2025 — Maintenance Training Program (PTM)
- IS 120-016D, of January 7, 2026 — Aircraft Maintenance Program (PMAC)