CAAB Air Operator Certificate (AOC) Readiness in Bangladesh

by Barrister Tahmidur Rahman | Sep 14, 2026

Trade, Competition & RegulationFrom application to first revenue flight8 min read

CAAB Air Operator Certificate (AOC) Readiness in Bangladesh

Air operator certificate readiness for new airlines, charter, cargo and helicopter operators in Bangladesh: we help sponsors structure the company, prepare for the Civil Aviation Authority of Bangladesh certification process, document aircraft leases and keep economic and safety approvals aligned through to launch.

CAAB Air Operator Certificate (AOC) Readiness in Bangladesh: Air operator certificate with TRW & Co
Matter planTrade, Competition & Regulation
  1. Feasibility and structure
  2. Pre-application preparation
  3. Application and evaluation
  4. Certification and beyond
Overview

What air operator certificate readiness involves

No commercial air transport operation can begin in Bangladesh without an air operator certificate issued by the Civil Aviation Authority of Bangladesh (CAAB). It confirms that an operator has the organisation, people, procedures, aircraft and maintenance arrangements to fly safely, and it is issued with operations specifications that set out what it may do. We advise sponsors of scheduled airlines, charter operators, cargo carriers and helicopter businesses on the legal and documentary side of that process, alongside the technical consultants and post holders who build the operational case. This work forms part of our regulatory practice in Bangladesh.

CAAB applies a phased certification process modelled on International Civil Aviation Organization guidance: pre-application discussions, a formal application, evaluation of manuals and documents, demonstrations and inspections, and finally issue of the certificate. Each phase depends on the previous one, and gaps found late can send an applicant back several steps. Air operator certificate readiness is therefore about sequencing as much as substance. We help applicants plan the corporate, contractual and regulatory milestones so that the company, its aircraft and its key personnel are all ready when CAAB expects them, rather than at different times.

The legal framework includes the Civil Aviation Act 2017, the Civil Aviation Authority Act 2017 and CAAB's Air Navigation Orders and related requirements, read with the ICAO annexes that Bangladesh has adopted. Safety certification is only one strand. A scheduled airline will usually also need economic authority from the government, route rights under air services agreements and approvals for each foreign destination. Leases, insurance, security programmes and dangerous goods arrangements must also be in place. An air operator certificate project that treats these as separate tasks risks a certified operator with nowhere it is permitted to fly.

Barrister Tahmidur Rahman advises on the investment, finance and leasing structures that sit behind a new operator, and Barrister Remura Meheruba Mahbub advises on corporate governance, foreign investment and banking issues, including foreign exchange approvals for lease rentals and maintenance reserves. Adv Syed Wahid, our founding partner, leads where a regulatory decision or commercial dispute needs to be taken to court. We work with counsel in the UK, US, UAE, China, India and Singapore when lessors, financiers or partner airlines are based abroad, which is common for any air operator certificate applicant leasing aircraft from international owners.

Our role in air operator certificate projects is legal and documentary, not technical. We do not write flight operations procedures or certify maintenance programmes, but we review how manuals, contracts and corporate documents fit together and whether they meet the legal requirements CAAB will test. That includes accountable manager authority, post holder appointments, outsourcing of maintenance, ground handling and training, and wet or dry lease approvals. If you are planning an airline or charter operation, or are part-way through an air operator certificate application, you can arrange an initial discussion through our Dhaka office.

01 · What we handle

Core workstreams

  • Corporate structure and ownership
  • Certification planning and filings
  • Aircraft leasing and registration
  • Outsourcing and service contracts
02 · How it runs

Four clear stages

  1. 01Feasibility and structure
  2. 02Pre-application preparation
  3. 03Application and evaluation
  4. 04Certification and beyond
03 · Start here

Talk to a partner

Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.

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How we help

What we handle

Workstream 01Trade, Competition & Regulation

Corporate structure and ownership

  • Feasibility and structure
  • Pre-application preparation
  • Application and evaluation
  • Certification and beyond
Workstream 02Trade, Competition & Regulation

Certification planning and filings

  • Feasibility and structure
  • Pre-application preparation
  • Application and evaluation
  • Certification and beyond
Workstream 03Trade, Competition & Regulation

Aircraft leasing and registration

  • Feasibility and structure
  • Pre-application preparation
  • Application and evaluation
  • Certification and beyond
Workstream 04Trade, Competition & Regulation

Outsourcing and service contracts

  • Feasibility and structure
  • Pre-application preparation
  • Application and evaluation
  • Certification and beyond
Workstream 05Trade, Competition & Regulation

Economic authority and route rights

  • Feasibility and structure
  • Pre-application preparation
  • Application and evaluation
  • Certification and beyond
Workstream 06Trade, Competition & Regulation

Ongoing compliance and enforcement

  • Feasibility and structure
  • Pre-application preparation
  • Application and evaluation
  • Certification and beyond
01

Corporate structure and ownership

We advise on incorporating the operating company, shareholder arrangements, board composition and the powers of the accountable manager, who must have authority to commit resources to safety. Where foreign investors are involved, we review ownership and control questions, Invest Bangladesh registration and Bangladesh Bank reporting, so that the applicant for the air operator certificate is structured in a way the regulator and the government can accept. Board resolutions and shareholder records should evidence who owns and controls the applicant, since the regulator will ask.

02

Certification planning and filings

We help prepare the pre-application statement of intent, the formal application package and the supporting legal documents, including evidence of incorporation, ownership, financial standing and key appointments. We track CAAB correspondence and findings, and maintain a document register so that each version of a manual, contract or appointment letter submitted for the air operator certificate can be identified and updated quickly. Findings are logged with owners and deadlines.

03

Aircraft leasing and registration

Most new operators lease their first aircraft. We review and negotiate dry and wet leases, return conditions, maintenance reserves, insurance and deregistration powers, and advise on registration of aircraft on the Bangladesh register and on CAAB approval of wet leases. We also advise on foreign exchange approvals for lease rentals and on tax treatment of payments to foreign lessors. Air operator certificate timing is reflected in delivery dates.

04

Outsourcing and service contracts

An operator remains responsible for activities it outsources. We draft and review contracts for maintenance, continuing airworthiness support, crew training, ground handling, fuel supply, catering and IT systems, making sure that oversight rights, audit access, quality standards and termination provisions allow the operator to demonstrate control to CAAB and to keep its air operator certificate in good standing. Agreements with maintenance providers and ground handlers should set measurable standards and give the operator audit and oversight rights.

05

Economic authority and route rights

Safety certification and permission to sell tickets on particular routes are separate. We advise scheduled and non-scheduled operators on the approvals needed from the Ministry of Civil Aviation and Tourism and CAAB, on designation under air services agreements, and on permits from foreign aviation authorities, coordinating with counsel abroad where an operator plans international services from Dhaka, Chattogram or Sylhet. Air operator certificate holders also need slot and airport approvals.

06

Ongoing compliance and enforcement

After certification, we advise on variations to operations specifications, adding aircraft types, changes of post holders, change of ownership, and renewal of key approvals. Where CAAB raises findings, suspends privileges or proposes enforcement action, we help prepare corrective action responses and, if needed, challenge decisions through administrative and court routes, while keeping the air operator certificate and commercial operations protected as far as possible.

RecognitionThe Legal 500Asia Pacific ranks Tahmidur Remura Wahid (TRW) Law Firm for dispute resolution in Bangladesh.
Cross-border reach6 jurisdictionsMatters coordinated with counsel in the UK, US, UAE, China, India and Singapore.
Bar and admissionsDhaka and LondonBarristers and advocates in Bangladesh, with a solicitor of England and Wales (non-practising).
HeadquartersDhakaHouse 410, Road 29, Mohakhali DOHS. Consultations in person or by video.
Who leads this work

Partner-led, on every matter.

Trade, Competition & Regulation matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.

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01

Who needs an air operator certificate in Bangladesh?

Any company that wants to carry passengers, cargo or mail for hire or reward by air needs an air operator certificate from CAAB. That includes scheduled domestic and international airlines, charter operators, air cargo carriers and commercial helicopter operators. Private flying for the owner's own purposes, flight training and aerial work may follow different approval routes, and the line between them can depend on how flights are sold and paid for. We review the business model first so that the applicant seeks the right category of permission and does not discover a gap at the inspection stage.

02

How long does the air operator certificate process usually take in Bangladesh?

It depends heavily on the applicant's preparation and the complexity of the operation. A helicopter charter operator with one type of aircraft presents a simpler case than a new jet airline planning international routes. Delays usually come from incomplete manuals, post holders who are not yet in place, aircraft that arrive late or lease approvals that lag behind the certification timetable. CAAB does not publish a guaranteed timeframe and we do not offer one. Instead, we help applicants build a realistic plan that lines up corporate, contractual and regulatory milestones and identifies the dependencies most likely to cause slippage.

03

What documents does CAAB expect to see with an air operator certificate application?

Applicants typically submit an operations manual, a maintenance control or continuing airworthiness manual, training programmes, a safety management system manual, a minimum equipment list, security and dangerous goods programmes and an emergency response plan. Alongside these sit legal documents: incorporation records, shareholder information, evidence of financial capacity, appointment letters and qualifications of post holders, aircraft lease and registration documents, insurance certificates and contracts with maintenance and handling providers. We focus on the legal documents and on whether it is consistent with the technical manuals, because contradictions between them are a common source of findings.

04

Can foreign investors own an airline in Bangladesh?

Foreign investment in aviation is possible, but ownership and control raise specific questions. Air services agreements often require designated airlines to be substantially owned and effectively controlled by nationals of the designating state, which can affect international route rights even where domestic law permits foreign shareholding. Government policy on foreign ownership in aviation has also changed over time. We review the current position, the proposed shareholding, board control and management rights, and the effect on future route designations, before the company applies for its air operator certificate. Getting this wrong can limit growth later.

05

Can we start with leased aircraft from a foreign operator?

Yes, many operators start with leased aircraft. A dry lease provides the aircraft alone, and the Bangladeshi operator supplies crew, maintenance and insurance under its own air operator certificate. A wet lease brings aircraft and crew from another operator, and requires CAAB approval and careful allocation of operational control and responsibility. Short-term wet leases are often used to cover peak demand or delays in delivery. We negotiate the commercial terms and the regulatory protections, including approval conditions, insurance, indemnities and the lessor's rights to deregister and export the aircraft on default. Each lease is reviewed against CAAB conditions.

06

What are the most common reasons applications stall?

Stalled applications usually share a few common causes. Key post holders are appointed late or do not meet experience requirements. Manuals are adapted from another operator without being tailored to the applicant's aircraft, routes and organisation. Contracts with maintenance providers or ground handlers do not give the operator the oversight rights it needs. Financial evidence is thin, or the corporate structure changes mid-process. We review the air operator certificate file as a whole, identify these weaknesses early and help the applicant fix them before CAAB inspectors do. A short legal audit often pays for itself.

07

What happens if the operator changes ownership or adds new aircraft types?

The certificate is tied to a specific operator, organisation and set of operations specifications. Adding a new aircraft type, changing the main base, replacing post holders or starting new kinds of operation usually requires prior approval or a variation. A change in ownership or control can also need regulatory consent and may affect route designations. We advise investors and operators on structuring such changes, preparing filings and building regulatory conditions into share purchase or investment agreements, so that a transaction does not put the air operator certificate or existing traffic rights at risk.

08

Can CAAB suspend or revoke an air operator certificate?

Yes. The regulator can vary, suspend or revoke a certificate where safety standards are not met, findings are not addressed or the holder no longer satisfies the conditions of issue. In serious cases, enforcement can be immediate. We help operators respond to findings with credible corrective action plans, communicate with the regulator and protect their position on the record. If a decision appears unlawful or disproportionate, our dispute resolution team can consider review or a writ petition, while recognising that courts give significant weight to safety concerns. Speed of response is often decisive.

How a matter runs

From first call to resolution.

  1. 01

    Feasibility and structure

    We review the business plan, fleet, routes and investors, advise on the company structure and ownership, and identify the safety, economic and foreign exchange approvals the project will need before any application is made. Early air operator certificate risks are flagged in writing.

  2. 02

    Pre-application preparation

    We prepare corporate and contractual documents, support the appointment of the accountable manager and post holders, and help assemble the pre-application package so that early meetings with CAAB are focused and productive. Recruitment timelines are tracked against the plan.

  3. 03

    Application and evaluation

    We coordinate submission of the formal application, maintain the document register, review responses to CAAB findings for legal consistency and track aircraft lease, registration and insurance steps in parallel. Weekly progress notes keep sponsors informed. Each open item is assigned an owner and a date and is reviewed until closed.

  4. 04

    Certification and beyond

    We support the final demonstration and inspection phase, review the certificate and operations specifications on issue, and then advise on variations, route approvals, new aircraft and ongoing compliance obligations. Renewal and review dates for the certificate and related approvals are diarised well ahead. Planned changes to routes, aircraft or key personnel are raised with the regulator in good time.

“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”

The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback

FAQ

Questions, answered.

Still unsure? Email info@trw.co with a short outline of the matter.

What is an air operator certificate?
It is the certificate CAAB issues to confirm that an operator has the organisation, personnel, procedures, aircraft and maintenance arrangements needed to conduct commercial air transport safely. It is accompanied by operations specifications listing the aircraft, areas of operation and special authorisations. Without a valid air operator certificate, a company cannot lawfully carry passengers or cargo for payment, even if it owns or leases suitable aircraft and has trained crew available. Operators should keep both documents current, because any change in fleet, base or type of operation must be reflected through an approved variation.
Is an air operator certificate the same as an airline licence?
No. The air operator certificate deals with safety and operational capability. Permission to operate scheduled services commercially, sell tickets and fly particular routes is a separate economic authority, and international services also depend on air services agreements and foreign permits. A new airline needs both strands in place before launch. Planning them together avoids the situation where a certified operator cannot yet sell flights. Investors should budget for both processes and assign responsibility for each strand at board level.
Who are post holders and why do they matter?
Post holders are the senior managers responsible for key areas such as flight operations, continuing airworthiness, crew training, ground operations, safety and quality. CAAB assesses their qualifications and experience, and their appointment is central to certification. Their contracts should reflect their regulatory responsibilities, reporting lines and authority. Delays in recruiting suitable post holders are one of the most frequent causes of slippage in an application timetable. Their employment terms should also address notice periods, so that a sudden departure does not leave a regulated position empty without a suitable deputy.
Do helicopter operators need an air operator certificate?
Yes, if they carry passengers or goods for hire or reward. Commercial helicopter services, including charter, corporate transport, tourism flights and some medical evacuation work, require certification. The scale of documentation may be smaller than for a jet airline, but the same principles apply: suitable organisation, trained personnel, approved maintenance and a working safety management system. We advise helicopter operators on corporate and contractual readiness. Contracts with corporate clients should also reflect the operator's control of flights and safety decisions.
Does TRW prepare operations manuals?
We do not write technical flight operations or maintenance procedures, which should be prepared by qualified aviation specialists. We review manuals for legal consistency with corporate documents, contracts and regulatory requirements, and we draft the legal documents that support the application. That division of work lets technical consultants and lawyers each focus on what they do best, while presenting CAAB with a coherent file. Where needed, we can suggest that clients engage independent aviation specialists.
How are lease payments to foreign lessors handled?
Remittances of lease rentals, maintenance reserves and related payments abroad are subject to Bangladesh foreign exchange rules and banking procedures, and may attract withholding tax depending on the nature of the payment and any applicable tax treaty. We advise on documenting leases so that banks can process payments smoothly, and on the approvals and tax filings that support remittances throughout the lease term. Lessors usually want clear gross-up and payment mechanics in the lease, so these points should be settled before signing.
Can an existing air operator certificate be transferred to a buyer?
Generally not. The certificate is issued to a specific operator on the basis of its organisation and personnel. A buyer of shares in the certificate holder acquires a company that continues to hold it, but a change of control may require regulatory consent. A buyer of assets alone would normally need its own certification. We review these issues in aviation acquisitions and build approvals into the deal timetable. Due diligence should also cover findings, open corrective actions and the status of key personnel.
How can TRW help an operator already in the process?
We can review the application file, CAAB correspondence and contracts, identify legal or documentary gaps and prioritise fixes. Operators sometimes bring in legal advisers part-way, often after early findings or a change in investors. We then work alongside the existing technical team, giving clear advice on corporate, leasing, foreign exchange and regulatory points that could otherwise hold up the air operator certificate. Our aim is to remove legal obstacles so that the technical team can concentrate on certification itself.

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