REQUIREMENTS FOR

PERMIT TO FLY AIRCRAFT

AIR NAVIGATION ORDER

VERSION : 7.0
DATE OF IMPLEMENTATION : 01-05-2024
OFFICE OF PRIME INTEREST : Airworthiness Directorate

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 REQUIREMENTS FOR PERMIT TO FLY AIRCRAFT

A. AUTHORITY:
A1. This Air Navigation Order (ANO) is issued by the Director General Pakistan Civil Aviation Authority
in pursuance of powers vested in him in terms of section 148 read with section 136 of the Pakistan Civil
Aviation Act, 2023.
B. PURPOSE:
B1. This ANO provides requirements for those who are seeking to obtain a ‘Permit to Fly’ (PtF) for an
aircraft that are not eligible for the issue of any type of Certificate of Airworthiness.
B2. This ANO prescribes requirements concerning the design, construction and certification of amateur
built aircraft and describes the PCAA role in the certification process.
B3. This ANO shall be read in conjunction with relevant requirements of Air Navigation Order issued
by Flight Standards Directorate of Pakistan CAA, ANO-021-FSXX for operational requirement of ‘Permit to
Fly’ Aircraft.
C. SCOPE:
C1. This ANO will be applicable to all organisations and personnel involved in design, construction,
building, certification and maintenance of Permit to Fly aircraft.
D. DESCRIPTION:
D1. DEFINITIONS:
The following terms when used in this ANO, have the meanings assigned to them respectively. Any term
used in this ANO but not defined, shall have the same meaning as given in the Pakistan Civil Aviation Act,
2023 and CARs 1994 provided they are not repugnant in the subject or content. For detailed definitions,
kindly refer to latest issue of AWNOT-017-AWRG.
D1.1 Permit to Fly aircraft: any aircraft having a mass greater than 50 kgs, which does not qualify for
the issuance of Type Certificate/ Certificate of Airworthiness and is not designated as Light Sport Aircraft
(as defined in ANO-018-AWRG) by manufacturing state shall be issued with a Permit to Fly (PtF) by PCAA
for operation in Pakistani airspace only.
D1.2 Amateur Built Aircraft: is defined as an aircraft of which a major portion (at least 51 percent) has
been fabricated and assembled by an individual or group of individuals. The construction of which is solely
for educational and/or recreational purposes. Such aircraft shall have maximum seating capacity of four
including pilot not exceeding 750 kg MTOW and its stall speed shall not exceed 45 Knots CAS
D1.3 Designated Technical Representative (DTR): is defined as an Aircraft Maintenance Engineer
License (AML) Holder in category B1 with ‘NIL’ Limitation having 10 years’ experience or AML Holder in
category B3 having 10 years’ experience or Aeronautical Engineer registered with PEC and having 5 years
of aviation experience
D1.4 Constructor: person or group of persons constructing an Amateur Built Aircraft
D1.5 Builder: person or group of persons building an aircraft other than Amateur Built Aircraft which are
not eligible for Certificate of Airworthiness
D2. GENERAL:
D2.1 PCAA is responsible for the airworthiness of aircraft that are on the Pakistan Aircraft Register and
requires compliance with the standards and detailed requirements contained in the Civil Aviation Rules,
1994 (CARs 1994) and other relevant PCAA Regulations.
D2.2 Issue and revalidation: Under the provisions of the ANO, permit to fly shall be issued to all aircraft
not qualified for Certificate of Airworthiness.
D2.3 The category / limitations in which vehicle has been categorized by the Regulatory Authority of the State of
Design will be acceptable. It will be the responsibility of the owner / operator to provide such data acceptable to PCAA.
Important Note: In case of any dispute regarding categorization of a vehicle; decision of the PCAA will be final.

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D2.4 When issued, the Permit to Fly will be valid for a period of two (02) years. In addition, aircraft issued
with a Permit to Fly may be required to undergo certain other periodic inspections in order to facilitate future
revalidations of the permit.
D2.5 Once expired, the PtF must be renewed before further flying is carried out. PtF shall not be
renewed for a period greater than two (02) years.
Note: The PtF shall be renewed on the same certificate by adding the new validity dates in the subsequent
rows till the time the rows runout. A new PtF certificate shall be issued once all the validity rows on the
previous PtF have been utilized.
D3. REGISTRATION:
D3.1 As per CARs 1994, an aircraft other than a military aircraft shall not fly in Pakistan unless it has
been included in the Pakistan Aircraft Register or has been registered in a contracting State.
D3.2 All Permit to Fly aircraft, are required to be registered and display the nationality and registration
marks as prescribed in CARs 1994. The Registration marks allotted to all aircraft which are not type
certificated will be AP-Z[XX] series.
D3.3 The following documents are required to be submitted to the Airworthiness Directorate for the
issuance of the Certificate of Registration:
D3.3.1 Submit a duly completed and signed application on current issue of CAAF-128-AWRG for
registration;
D3.3.2 Attested copy of owner’s CNIC
D3.3.3 Bill of Sale, purchase Agreement or anything equivalent in original or notarized copy;
D3.3.4 No Registration Certificate or de-registration certificate (as applicable);
D3.3.5 Power of Attorney or delegation letter from the owner of the vehicle, if the application is
not submitted and signed by the owner himself;
D3.3.6 Custom Clearance documents;
D3.3.7 Requisite fee in accordance with current AWNOT-003

D4. CRITERIA FOR THE ISSUANCE OF A PERMIT TO FLY

D4.1 General Requirements: The process associated with the issue of a Permit to Fly follows the same
basic steps irrespective of the aircraft type. The general requirements are listed below:
D4.1.1 Certificate of Registration in favor of the aircraft has been issued.
D4.1.2 An application for a Permit to Fly must be made on current issue of CAAF-135-AWRG.
D4.1.3 The aircraft design basis must be reviewed and documented.
D4.1.4 The standard of maintenance must meet constructor/builder requirements to ensure that
aircraft is fit to fly.
D4.1.5 The aircraft must be test-flown.
D4.1.6 The aircraft construction/build record (If applicable), modification record, maintenance
record and operating history shall be available.
D4.2 A Permit to Fly will not be issued to an aircraft which has formerly been issued with a Certificate of
Airworthiness in normal category by an ICAO contracting state, unless it is no longer possible to fulfil the
requirements for the issue of a Certificate of Airworthiness.
D4.3 Permit to fly Aircraft: The application for issuance of permit to fly aircraft shall be submitted on
the current issue of CAAF-135-AWRG to HQs. Airworthiness Directorate. For initial issuance, HQs.
Airworthiness Directorate will nominate inspector from Local Airworthiness Field offices to carry out
inspection of the aircraft to ensure that the aircraft meets following minimum requirements for issuance of
a permit to fly.
D4.3.1 The permit to fly aircraft shall be equipped with the following minimum flight instruments:
i. A magnetic compass

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ii. One Altimeter

iii. One Airspeed Indicator
iv. A rate-of-climb and descent indicator (Vertical Speed Indicator)
v. Any means of two-way communication

D4.3.2 Permit to fly aircraft are to be equipped with aviation grade shoulder harnesses and seat
belts preferably certified on aviation standards.
D4.3.3 The Permit to fly aircraft should be constructed/built by a renowned organization accepted
by the concerned regulatory authority of that country if constructed/built outside Pakistan.
D4.3.4 The placard shall be displayed on the aircraft in full view of the pilot as follows: “WARNING:
This aircraft is not issued with a Certificate of Airworthiness".
D4.3.5 All Permit to Fly aircraft, which is registered in Pakistan, shall not be flown over water at a
distance of 93kms or more from land, or over areas where search and rescue would be
difficult unless it carries an Emergency Locator Transmitter (ELT). For further information,
refer the latest issue of the Airworthiness Notice No. AWNOT-057-AWRG.
D4.3.6 All Permit to Fly aircraft does not require Radio Installation Certificate (RIC) for its
operation
D4.3.7 Unless authorized a deviation from Air Traffic Control, an aircraft which is equipped with
Mode C transponder shall possess a calibrated airspeed / static pressure system to
prevent an error in altitude reporting. The Mode C transponder must be tested and
inspected as per requirements of PCAA.
D4.4 After the inspection, the nominated inspector shall send their recommendations to HQs.
Airworthiness Directorate along with relevant conditions (if any).
D4.5 Upon successful scrutiny, a Permit to Fly shall be issued by HQs. Airworthiness Directorate on
CAAF-008-AWRG along with list of relevant conditions as recommended by the nominated inspectors.
D4.6 The application shall be submitted to local Airworthiness field office for renewal of PtF, by the
operator. The field office shall renew the Permit to Fly for a period not exceeding two (02) years from the
date of expiry, based on inspection carried out pertaining to aircraft record, general physical condition of
aircraft and compliance of requirements mentioned in D4.3 above.
D5. DESIGN, CONSTRUCTION AND CERTIFICATION OF AN AMATEUR BUILT
AIRCRAFT
D5.1 A person or group of persons intending to construct an amateur built aircraft must contact a DTR
to supervise the whole project on behalf of PCAA.
D5.2 The prospective constructor should contact the principal Airworthiness field office in order to
discuss the plans for constructing the aircraft. The PCAA Airworthiness inspector may provide the
prospective constructor with guidance necessary to ensure a thorough understanding of applicable
regulations. During this contact, the type of aircraft, its complexity, manufacturing process, and use of
materials should be discussed.
D5.3 DTR shall evaluate the plan for intended aircraft constructor and submit a report along with its
recommendations to PCAA for review/analysis. This shall include:
D5.3.1 Clearly stating the route, which the constructor wants to adopt, from following:
D5.3.1.1 Design and construct on your own from scratch; or
D5.3.1.2 Construct from plans to someone else’s design; or
D5.3.1.3 Construction from a kit
D5.3.2 Finalization of facility and premises in which the construction will undertake
D5.3.3 Utilization of CAAF-221-AWRG to establish the eligibility of an aircraft as an amateur built
aircraft by determining that that major portion of the aircraft is fabricated and assembled
by the constructor

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D5.3.4 Identifying the pre-determined stages at which PCAA will inspect the progress for
ensuring:
D5.3.4.1 acceptable standards of workmanship are being achieved;
D5.3.4.2 good aeronautical engineering practices are being observed;
D5.3.4.3 the quality of the product is adequate; and
D5.3.4.4 proper usage of tools, materials and equipment
D5.3.5 Documentation, which will be used to record the construction of the aircraft

D5.4 The plan should be finalized in presence of the DTR and should be acceptable to PCAA
D5.5 After finalization of the plan, the constructor should ensure the following during construction of the
amateur built aircraft:
D5.5.1 Document the construction using photographs taken at appropriate times prior to covering.
The photographs should clearly show methods of construction and quality of workmanship.
Such photography records should be included with the constructors’ log or other
construction records
D5.5.2 The aircraft and its component parts shall be available at pre-determined stages during
construction for their inspection by an officer from Airworthiness Directorate
D5.5.3 Progressive report and documents should be available at all time for the inspection of
Airworthiness Officer. This report shall be formulated under the supervision of DTR and
should include following details:
D5.5.3.1 The address of work place where aircraft is being constructed;
D5.5.3.2 A brief description of the workshop-space, tools and facilities, which will be
available for construction of aircraft;
D5.5.3.3 An outline of the procedures / processes followed in constructing the aircraft and
controlling / identifying the materials used;
D5.5.3.4 Drawing and associated dimensional data and material specifications and
necessary instructions / processes of the aircraft to be constructed;
D5.5.3.5 Particulars of the persons or person/s who will construct the aircraft, listing their
trade skill and engineering and aeronautical qualifications and experience;
D5.5.4 If specified processes such as welding, gluing or bonding etc., to be performed on primary
structure, the constructor shall state what arrangements have been made for qualified
persons or approved organizations to carry out the work as per aviation
standards/specifications
D5.5.5 The constructor of an aircraft is required to demonstrate its competence in particular
construction techniques before doing specialized works e.g. working with composite
materials, riveting, glued joints etc
D5.5.6 Materials and parts to be used on aircraft shall be covered by Release Note or equivalent.
The documents detailing use of materials shall be retained in the constructional record

D5.6 Following are the guidelines provided to amateur built aircraft constructor as acceptable to PCAA:
D5.6.1 Any choice of engines, propellers, wheels, other components, and any choice of materials,
may be used in the construction of amateur-built aircraft. However, it is mandatory that
only approved components and established aircraft quality material be used in fabricating
parts constituting the primary structure, such as wing spars, critical attachment fittings,
and fuselage structural members. Inferior or sub-standard materials, whose identity
cannot be established, should not be used. The use of major sections (i.e., wings,
fuselage, empennage, etc.) from type-certificated aircraft may be used in the construction
process as long as these sections are in satisfactory condition for safe operation.
D5.6.2 The design of the cockpit or cabin of the aircraft should avoid, sharp corners or edges,
protrusions, knobs and similar objects which may cause injury to the pilot or passengers
in the event of an accident. It is strongly recommended that approved seat belts be
installed along with approved shoulder harnesses

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D5.6.3 In engine installation, it must be ensured that adequate fuel is supplied to the engine in all
anticipated flight attitudes. Also a suitable means, consistent with the size and complexity
of the aircraft, should be provided to reduce fire hazard wherever possible, including a
fireproof firewall between the engine compartment and the cabin. When applicable, a
carburetor heat system should also be provided to minimize the possibility of carburetor
icing
D5.6.4 No locally manufactured engine, propeller or airframe parts (load bearing members)
should be used in the construction of aircraft.
D5.6.5 The engine to be installed in the aircraft shall be either new or newly overhauled or if
removed from another aircraft with un-expired life (TBO), it must be inspected and
appropriately certified as serviceable in the engine logbook
D5.6.6 In case of construction from purchased plans, consultation with the designer of purchased
plans may be furnished
D5.6.7 In case of construction from a kit, the major portion of a kit should be composed of raw
stock, such as lengths of wood, tubing, extrusions, etc, which may have been cut to an
approximate length. Prefabricated parts, such as heat treated ribs, bulk heads or complex
parts made from sheet metal, fiber glass, or polystyrene would also be acceptable. Kits
may include assembly jigs, templates, raw stock or other means to simplify the fabrication
and assembly process
D5.6.8 Builder of aircraft kit should have minimum of 3 years of manufacturing experience. The
aircraft constructed/built from that kit must have a minimum of 1000 hrs accumulative flying
data available. The statement of the kit builder is required, certifying the compliance of
aforesaid requirements
D5.7 After completion of construction of the aircraft, the applicant will submit the following:
D5.7.1 Final report of the aircraft duly signed by the DTR covering all details mentioned in D5.5.3
D5.7.2 Statement certifying that the major portion was fabricated and assembled and evidence to
support this statement.
D5.7.3 Evidence of inspections, such as logbook entries signed by the constructor and supervised
by the DTR, describing all inspections conducted during construction of the aircraft in
addition to photographic documentation of construction details. This will substantiate that
the construction has been accomplished in accordance with acceptable workmanship
methods, techniques, aviation standards and practices
D5.7.4 Construction record
D5.7.5 Provisional Flight Manual
D5.7.6 Maintenance Schedule
D5.7.7 The complete weight and balance report, including load limits for crew, oil, fuel and
baggage, which should be accurately weighed in accordance with established weight and
balance procedures in order to determine the aircraft’s empty weight, gross weight and
centre of gravity range, including the weight and balance for the initial flight test in order to
help reduce stall, spin, and other control related accidents. Such limits should be
determined by the constructor through calculations in case the aircraft is self-designed, or
as specified in the data for aircraft constructed from kit or purchased plans.
D5.8 After inspection of documents and data submitted with the application, the Airworthiness inspector
will perform inspection of the Aircraft. Upon confirmation that the Aircraft has been properly constructed
under the provision of applicable regulation and procedure, the Airworthiness inspector shall forward the
provisional Flight Manual to PCAA Flight Standard Directorate for its finalization and for issuance of
appropriate operating limitations acceptable to PCAA FSD.
D5.9 At this stage, aircraft will be registered as per Para D3 above. PCAA AWD will initially issue the
aircraft with a Permit to Fly for 40 Flight Hours for flight testing with the limitation of operating in an assigned
test area by ATC on FSD recommendation. Flight Hours for test flight may also be extended if deemed
necessary to finalise the performance, operating limitations and Aircraft Flight Manual. Extension of validity
of Permit to Fly beyond 40 Flight Hours for flight test will be granted by PCAA AWD on the recommendation
of PCAA FSD. All criteria for the issuance of Permit to Fly shall be met as per Para D4 above.

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D5.10 Once the Aircraft performance, operating limitation and Flight Manual is finalized with the
acceptance of FSD, the applicant will submit the application to PCAA AWD in accordance with Para D4 for
issuance of regular Permit to Fly to the Amateur Built Aircraft, which will also include finalized Aircraft Flight
Manual accepted by PCAA FSD.
NOTE: Please consult the EASA CS-VLA document for guidance and a template regarding the Flight
Manual.
D6. AMATEUR BUILT AIRCRAFT CONSTRUCTED OUTSIDE PAKISTAN AND
PURCHASED BY PAKISTANI CITIZENS
D6.1 When a Pakistani citizen purchases such aircraft, acceptable procedures for obtaining
airworthiness certification for amateur-built operations are as follows:
D6.1.1 The previous owner should have conducted condition/annual type inspection performed
on the aircraft
D6.1.2 The previous owner should obtain documentation from the concerned Civil Aviation
Authority that verifies the aircraft is/was originally certificated in that country as an
amateur-built aircraft
D6.1.3 The new owner of such aircraft shall present to PCAA Airworthiness Directorate, the
following documentation:
D6.1.3.1 Request for NOC for the import of the aircraft;
D6.1.3.2 Custom clearance document;
D6.1.3.3 De-registration certificate from country of previous registration;
D6.1.3.4 Aircraft Documents for acceptance such as Maintenance Schedule, Aircraft
Flight Manual, Operating Limitation, etc.;
D6.1.4 The owner should apply for PCAA certificates as per Para D3 and D4

D7. MODIFYING OR REPAIRING A PERMIT TO FLY AIRCRAFT

D7.1 Any modification carried out on the aircraft issued with Permit to Fly shall have concurrence from
its builder or constructor. Failing to comply with these instructions will lead to invalidation of the Permit to
Fly.
D7.2 All modifications and repairs carried out on the aircraft with the concurrence of builder or
constructor will be acceptable to PCAA provided PCAA AWD is properly intimated about such modifications
and repairs. In case where builder or constructor support is not available, such modification or repair should
be properly evaluated and accepted by DTR.
D8. Maintenance Inspection requirements for an Aircraft Issued with a Permit to Fly
D8.1 The responsibility rests with the aircraft owner who must ensure that the aircraft is serviced and
inspected periodically. Maintenance must be carried out methodically to a maintenance schedule provided
by the builder/constructor of aircraft to ensure that the inspections are timely and appropriate.
D8.2 A record of the inspections and checks, as well as any defects found, must be kept so that a history
of the aircraft can be built up. The entries of work carried out should be recorded in the aircraft engine and
propeller log books (Refer Appendix A of this ANO). The entries must include details of inspections, repairs,
replacements, modifications and overhauls carried out. It should be noted that whilst the log books may
contain a summary of the work carried out, the extent to which this can be done may be dependent upon
the existence of more detailed inspection worksheets. These will, in turn, form part of the aircraft logbook
and must be retained.
D8.3 The owner / operator shall be registered with the constructor or builder and have a valid
subscription for supply of modifications and revision of maintenance instructions as and when issued.
D8.4 If the engine installed on these aircraft becomes restricted initially by ‘calendar period limitation’ of
a recommended overhaul period (TBO), it may continue in service until the ‘operating limitation’ of TBO is
reached or maximum of 36 months period have been elapsed, whichever comes first.

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D8.5 In case of engine reaching ‘operating life limitation’ of TBO, it may continue in service for a further
period of operation not exceeding 20% of the recommended operating limit of TBO
D8.6 In both cases, extension will only be availed if the engine has been under continuous condition
monitoring and its results are satisfactory.
D8.7 Satisfactorily results along with the permissible extension shall be properly recorded in Engine
Logbook.
D8.8 All kind of maintenance shall be certified by the owner, DTR or appropriate PCAA ANO-066 basic
AML holder with maximum limitation of 1 & 9.
D9. Mandatory Safety Requirements:
D9.1 If considered necessary, in the interest of safety, the Airworthiness Directorate or DTR may
suspend or stop the operation of Permit to fly aircraft or specify additional conditions to be followed.
D9.2 Log Books in respect of Permit to fly aircraft shall be maintained as per Appendix 'A'.
D9.3 Full compliance must be ensured in respect of Civil Aviation Rules 1994 and the CAA requirements
prescribed under these rules. The defects/incident/accident shall be reported as per latest version of the
Airworthiness Notice AWNOT-009.
D9.4 Owner is responsible to check the quality of fuel and undertake all necessary steps while refueling
so that quality of the fuel is not degraded and safety of surrounding area is ensured. Owner is also
responsible to ensure that the aircraft’s mass and balance is within limits for the operating conditions.

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APPENDIX -A

Permit to fly aircraft Logbook

Instructions:

1. All pages of the logbook shall have a serial number.

2. The entries in this logbook shall be made in Ink and signed by the owner or by PCAA ANO-
066 basic AML holder in Category B1 with maximum limitation of 1 & 9 or AML holder in
Category B2 or B3 or DTR.

3. No entry shall be erased and no page shall be removed.

4. Periodic maintenance, component changes, repairs and modifications shall be recorded on

the right hand side page with full particulars of the item, date of accomplishment and the
particulars of the incumbent performing the activity.

5. Such information as constructor’s notes, aircraft inspection record, rigging and installation
diagrams shall be affixed to the binding slip provided for the purpose.

6. One line shall be used for all flights of a day.

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APPENDIX -A

Details of Permit to fly aircraft

1. Type of Vehicle (Tick one)

 Amateur Built
 Others

2. Nationality and Registration Mark

3. Owner:

3.1 Name:

3.2 Address:

4. Builder/Constructor:

5. Date of Manufacturing:

6. Engine Manufacturer:

7. Engine Type/ Model:

8. Propeller Manufacturer: _____________________________________________

9. Propeller Type i.e. (fixed pitch, variable pitch etc.):

10. Maximum Take-off Gross Weight:

11. Empty Weight (Excluding fuel, floats, safety equip, etc):

12. Fuel Capacity (US Gallons):

13. Cruising Speed (At full Power):

14. Power off Stall Speed:

Certificate to Service

This is to certify that the Permit to fly aircraft bearing the above registration mark will be maintained as per
manufacturer’s/builder’s/constructor’s and CAA’s instructions. The undersigned is responsible for proper
maintenance of the vehicle and for conducting safe operation.

Date: Signatures of Owner/Operator/AML/DTR:

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APPENDIX -A

LOG BOOK – Airframe

(Running Pages on Left Hand Side)

DATE HOURS FLOWN CYCLES FLOWN SIGNATURE

Note:- 1. There should be 50 such pages in a log book.

2. Pages will be numbered 1,2,3,……………50.

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APPENDIX -A

LOG BOOK Airframe

(Running Pages on Right Hand Side)

Periodic Maintenance, Component Changes, Repair,

Signature and Date
Modifications, Major Defects/Incidents/Accidents Details

Note:- 1. There should be 50 such pages in a log book.

2. Pages will be numbered 1A,2A,3A,……………50A.

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 REQUIREMENTS FOR PERMIT TO FLY AIRCRAFT
APPENDIX -A

LOG BOOK – Engine and Propeller

(Running Pages on Left Hand Side)

DATE HOURS FLOWN CYCLES FLOWN SIGNATURE

Note:- 1. There should be 50 such pages in a log book.

2. Pages will be numbered 1,2,3,……………50.

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 REQUIREMENTS FOR PERMIT TO FLY AIRCRAFT
APPENDIX -A

LOG BOOK Engine and Propeller

(Running Pages on Right Hand Side)

Periodic Maintenance, Component Changes, Repair, Modifications,

Signature and Date
Overhaul, Major Defects/Incidents/Accidents Details

Note:- 1. There should be 50 such pages in a log book.

2. Pages will be numbered 1A,2A,3A,……………5

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