New Delhi, India: The Directorate General of Civil Aviation (DGCA) has issued a draft revision to the Civil Aviation Requirement (CAR) governing Approved Training Organisations (ATOs) that provide aircraft type-rating training to flight crew, proposing tighter requirements for safety management, quality assurance, staffing, training facilities, examinations and regulatory oversight. Stakeholders have been given until September 25, 2026, to submit their comments on the proposed framework. The draft is listed by the DGCA as a revision to CAR Section 7, Series D, Part IV, covering “Approved Training Organizations (ATOs) For Type Rating Of Flight Crew.”
The proposed CAR states that it is issued under Rules 29C, 133A and 133B of the Aircraft Rules, 1937, and sets out the requirements for organisations seeking DGCA approval to provide aircraft type-rating training to flight crew. The regulator defines an ATO as an organisation approved by and operating under DGCA supervision to provide approved training, with approval dependent on the organisation demonstrating that it is appropriately staffed, equipped, financially resourced and capable of meeting the required standards.
Under the draft, approved flight-crew training is to be conducted through an ATO. However, recognising a shortage of training organisations, the framework allows ATOs to conduct type-rating recurrent training and other training approved by the DGCA. Organisations wishing to provide such additional training would have to include it in their Training Procedure Manual.
The draft requires an ATO to develop a separate training programme for every type of course it offers, with each programme requiring DGCA approval before implementation. The organisation’s Training Procedure Manual must describe the scope of authorised training, course content, courseware and equipment, facilities, quality assurance arrangements, responsibilities and qualifications of training personnel, training-record procedures and, where applicable, procedures for examinations conducted on behalf of the regulator.
The proposed framework also provides for DGCA-authorised examinations. Where an ATO is authorised to conduct examinations required for the issue of a licence or rating, the examination would have to be conducted by personnel authorised by DGCA or by personnel designated by the ATO under DGCA-approved criteria. Electronic examinations would also be permitted if the relevant procedures are incorporated into the Training Procedure Manual.
Safety management is a major component of the proposed rules. The DGCA says an ATO exposed to safety risks while providing its services must implement a Safety Management System acceptable to the regulator. The system would have to identify safety hazards, ensure remedial action, continuously monitor and assess safety performance and pursue continuous improvement. The draft specifically requires clear safety-accountability lines throughout the organisation, including “direct accountability for safety on the part of senior management.”
The proposed SMS framework includes safety policy and objectives, safety accountabilities, appointment of key safety personnel, coordination of emergency-response planning and SMS documentation. ATOs would also have to maintain formal processes for hazard identification, safety-risk assessment and mitigation, safety-performance monitoring, management of organisational change and continuous improvement. Safety training would have to be provided to personnel according to their responsibilities within the SMS.
The draft separately strengthens quality-assurance requirements. Every ATO would have to establish a quality-assurance system acceptable to DGCA, including a defined audit schedule and periodic review cycle. All aspects of training would have to be reviewed within a 12-month period. The regulator says “Accurate, complete, and readily accessible records” of the quality-assurance programme must be maintained, with audit schedules, inspection and audit reports, responses to findings, corrective-action reports, follow-up and closure reports, and management-evaluation reports retained for five years.
An ATO seeking certification would also have to establish procedures to ensure continuing compliance with applicable regulatory requirements and maintain a quality system capable of detecting deficiencies for self-remedial action. The organisation would be required to submit a Quality Manual for DGCA acceptance and provide the Flight Standards Directorate with audit reports and details of remedial action at least annually and before its annual inspection.
The proposed rules set out responsibilities for the Quality Manager, who would be approved by DGCA and would have direct access to the Head of Training and Accountable Manager as well as access to all parts of the ATO. For small or very small organisations, the Head of Training and Quality Manager positions could be combined, but quality audits would have to be conducted independently. The draft classifies organisations with five or fewer instructors as very small and those with six to 20 instructors as small.
The draft also permits ATOs to subcontract certain activities to external organisations, subject to DGCA approval. However, the ultimate responsibility for the training would remain with the approved ATO. A written agreement would be required to define the safety-related services and quality standards, while subcontractors’ relevant activities would have to be included in the ATO’s quality-assurance programme. Their facilities, working environment, authorisations and competence would also have to be acceptable to DGCA.
The proposed framework contains detailed requirements for training facilities and equipment. ATOs would have to possess or have access to the information, equipment, training devices and material needed for their approved courses. Flight Simulation Training Devices could be owned or leased, but they would have to be operated by the ATO. Synthetic training devices would need to be qualified under DGCA requirements, with their use approved by the regulator.
Classrooms would have to be suitably equipped, adequately ventilated and protected from external noise and distractions. A separate room suitable for theoretical-knowledge examinations would also be required, although it could be the same room used for instruction if specified conditions were met. The draft additionally requires appropriate safety and security systems at ATO facilities.
The draft places specific requirements on the organisation’s senior training personnel. An ATO would have to employ the necessary personnel to plan, conduct and supervise training, while instructional personnel would have to receive initial and continuation training appropriate to their duties. The proposed post-holder structure includes an Accountable Manager, Head of Training, Chief Instructor/Chief Flying Instructor, Chief Ground Instructor, Chief Synthetic Flight Instructor where applicable, Quality Manager and, where relevant, a Director or Head of Maintenance.
The Head of Training would be responsible to DGCA for the training organisation’s activities and would require DGCA approval. The draft says the person should have extensive training experience as a Designated Examiner, Synthetic Flight Instructor or Type Rating Instructor, together with appropriate managerial capability. The Head of Training would also oversee flight, theoretical-knowledge and synthetic-flight training records and monitor simulator-related issues, including the impact of reported simulator defects on training.
The Chief Flight Instructor would be responsible for student flight and synthetic-flight training records and course-completion certification arrangements. The draft requires the person to have held the highest professional pilot licence and relevant ratings for the training being conducted, along with appropriate DE/TRI/SFI experience. It also proposes a requirement for 1,000 hours as pilot-in-command on the relevant aircraft type, of which at least 500 hours would be on flying duties related to the training courses and up to 200 hours could be instrument ground time.
The Chief Ground Instructor would supervise ground instructors and standardise theoretical-knowledge instruction. The Chief Synthetic Flight Instructor, where required by the training scope, would oversee synthetic-flight training. The draft also sets out qualifications and responsibilities for maintenance personnel where training aircraft are used.
The proposed rules require sufficient instructors to ensure continuity of training. Instructional staff would generally not be permitted to work in more than one DGCA-approved training organisation unless the regulator expressly permits it. Flight instructors would need the appropriate professional licence, rating and instructor qualification or DGCA authorisation for the training they conduct.
The DGCA also proposes stronger requirements for monitoring training effectiveness. The regulator would monitor an ATO to determine the proportion of trainees subsequently found to lack required skills or proficiency. Repeated deficiencies would be treated as unsatisfactory and would require remedial action by the ATO. The draft also allows DGCA to take immediate action where it considers that training standards have deteriorated to a level that could affect cadets or safety.
Certification would not automatically continue simply because an ATO had previously been approved. The draft states that continuation would depend on the outcome of DGCA inspections. The regulator would retain the power to re-inspect an organisation at any time during its certification period and to sample ground, flight or synthetic-flight training, including briefings, debriefings and training records.
The proposed ATO approval would be valid for five years from the date of issue, while renewal applications would have to be submitted at least 30 working days before expiry. Renewal applications would have to include the internal audit report, action-taken report, a statement on rectified discrepancies and the applicable fee. The draft states that all ATOs would be given a five-year renewal.
The regulator has also proposed explicit enforcement provisions. Failure to comply with applicable requirements could lead to administrative penalties, suspension, cancellation or revocation of an ATO certificate. Training conducted in breach of an ATO certificate condition could be treated as unauthorised training and could attract enforcement action even if the breach was detected later.
DGCA would maintain an effective oversight programme for approved training organisations, while the draft proposes publication of an annual surveillance plan for ATOs on the DGCA website. The examination provisions would continue to require DGCA authorisation or DGCA-approved criteria where an ATO is permitted to conduct licensing examinations.
The draft also addresses the transfer of students between ATOs. Training is expected to be completed as a continuous course at one approved organisation. Where there are valid reasons for transferring, however, credit can be given for completed training. The new ATO’s Head of Training would have to assess the student’s previous training and determine what additional training is necessary. Certified copies of training records would have to be provided to the new ATO and the DGCA Licensing Directorate informed of the transfer.
The proposed fee for ATO approval would remain linked to Rule 133C of the Aircraft Rules, 1937. The draft concludes with an appendix setting out the framework for Safety Management Systems, including safety policy, accountability, key safety personnel, emergency-response coordination, SMS documentation, hazard identification, risk assessment and mitigation, safety-performance monitoring, management of change, continuous improvement and safety promotion.
The DGCA’s proposal is intended to establish a more structured regulatory framework for organisations providing aircraft type-rating training to flight crew, while allowing approved organisations to undertake certain additional training and, where authorised, examinations on behalf of the regulator. The New Indian Express reported that such organisations may be permitted to conduct examinations where their infrastructure and quality-assurance systems are considered satisfactory.
The proposal remains a draft and is therefore not yet the final regulatory requirement. DGCA has invited stakeholders to submit comments on the proposed revision until September 25, 2026. The regulator’s official website lists the draft under its requirements and guidance framework, with the website itself showing a last-updated date of August 31, 2026.
