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Aruba and San Marino Agree New Regulatory Oversight Framework for Commercially Operated Aircraft

Why It MattersCross-registry commercial arrangements depend on bilateral oversight agreements that split airworthiness and inspection duties between registry and operator states without merging their regulatory authority.

What happened

The Department of Civil Aviation Aruba (DCA-A) and the San Marino Civil Aviation Authority (SM-CAA) signed a new regulatory oversight framework on September 7 covering San Marino-registered aircraft that operate commercially under an air operator certificate (AOC) issued by Aruba. San Marino acts as the state of registry and Aruba as the state of operator. The framework is established under Article 83 of the Convention on International Civil Aviation and does not transfer regulatory functions or duties between the two authorities.

Aruba and San Marino Agree New Regulatory Oversight Framework for Commercially Operated Aircraft

Under the arrangement, SM-CAA retains responsibility for issuing and reissuing Certificates of Airworthiness, while DCA-A verifies their validity and ensures operators maintain procedures to keep those certificates in force. The two authorities share complementary tasks on continuing airworthiness, including maintenance programmes, maintenance control procedures, modifications and repairs, and the exchange of airworthiness information. SM-CAA will have access to relevant DCA-A documentation, and DCA-A will facilitate on-site inspections conducted by SM-CAA in Aruba. Aircraft covered by the arrangement will be identified by type, registration mark and serial number and listed in a dedicated schedule. Representatives of both authorities will meet annually to review safety oversight activities, with dedicated focal points maintaining regular communication.

Sir Jorge Colindres, executive chairman and founder of The Registry of Aruba, said the agreement "strengthens the relationship between our two jurisdictions while creating a clear framework for aircraft owners and operators whose registration and commercial operating requirements span San Marino and Aruba." David Colindres, president of the San Marino Aircraft Registry, said the framework "provides qualifying owners and operators with a clear framework for combining San Marino registration with commercial operation under an Aruba AOC, while ensuring that both civil aviation authorities remain closely coordinated throughout the operation of the aircraft."

Industry impact & what to watch

This agreement belongs to a familiar category of aviation regulation: bilateral arrangements under Article 83 that let an aircraft's state of registry and its state of operator split oversight duties without either side ceding authority. Such frameworks let owners keep a preferred flag registration while still meeting the commercial-operating requirements of the jurisdiction issuing the AOC, which matters for registries like San Marino and Aruba that compete for aircraft owners across borders.

How the split works in practice is defined largely by who signs off on what: SM-CAA keeps the authority to issue Certificates of Airworthiness, DCA-A checks their validity and operator procedures, and continuing-airworthiness tasks such as maintenance programmes and repairs are shared. The annual review meetings and named focal points are the mechanism meant to keep that division from breaking down as aircraft move between the two authorities' oversight.

What happens next is whether owners and operators actually use the framework — the schedule listing eligible aircraft by type, registration mark and serial number will show how many aircraft are brought under it, and the first annual safety oversight review between DCA-A and SM-CAA will be the first test of how the coordination works in practice.

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