The Royal Federation of Aero Clubs of Australia (RFACA) has called on the Australian Government and CASA to reconsider the need for a new annual VH aircraft registration levy, after CASA’s own consultation found widespread concern about the cost, necessity and design of the proposed scheme.
CASA received 718 submissions to its consultation on annual VH aircraft registration, 20% of them lodged on behalf of organisations. In its consultation summary, CASA said feedback was ‘dominated by concerns about the introduction of an annual charge’, with many respondents questioning the need for annual registration and warning of future fee escalation.
While CASA concluded that no recurring theme had emerged that would make the scheme unworkable, RFACA President Lachlan Hyde said the findings showed significant questions about the case for the levy remained unresolved.
‘There is an important distinction between supporting an accurate, modern aircraft register and accepting that every VH aircraft needs another recurring annual regulatory charge attached to it,’ Mr Hyde said.
‘CASA’s own summary confirms that many people across aviation are asking the same fundamental question we raised: can better data be achieved through modern digital systems, targeted validation and existing regulatory obligations without creating another perpetual cost for industry? The issue isn’t whether $50 or $72 sounds like a large amount in isolation. It is what happens when aviation operators are continually asked to absorb another $50 here and another $100 there, on top of rising fuel, maintenance, insurance, airport, security and regulatory costs.’
Annual VH registration is due to begin from July 2027, with the levy proposed to commence from 1 July 2028. CASA estimates the scheme will cost about $1.08 million annually to administer, with illustrative options ranging from around $72 per aircraft under a flat-rate model, to $50 to $250 under a weight-based model and $40 to $500 under a weight-and-category model. More than three-quarters of Australia’s 15,051 active aircraft would fall below 2,000 kg under the proposed weight-based model.
RFACA opposed the flat-rate option, arguing it would place a disproportionate share of the scheme’s cost on general aviation, and said a weight-based model would be a more reasonable starting point if a levy proceeds, alongside concessions or exemptions for not-for-profit aero clubs, training aircraft, heritage and restoration aircraft, and aircraft temporarily out of service.
Published submissions reveal sharply different industry views
Published submissions to the consultation reveal how differently the sector views the proposal.
The Australian Mooney Pilots Association (AMPA) was unequivocal: ‘AMPA opposes the introduction of an annual registration charge in any form.’ It argued any levy, if introduced, should be capped at CASA’s lowest illustrative charging level. The Aero Club of Southern Tasmania agreed: ‘We oppose the introduction of a levy,’ while supporting a modernised register achieved through digitisation rather than a recurring fee.
The Regional Aviation Association of Australia (RAAA) took the opposite position, backing CASA’s illustrative $72 flat-rate levy. ‘The administrative burden for CASA to register an Airbus A380 or a Cessna C172 aircraft is exactly the same,’ it told CASA, opposing both weight-based models.
Gliding Australia raised a different concern again, warning that CASA already funds it to maintain the glider portion of the aircraft register: ‘This creates a risk of duplicate processes and possible double cost recovery.’ It called for aircraft under its existing arrangements to be exempted from the new process.
The Royal Flying Doctor Service South Eastern Section, meanwhile, supported annual registration outright, citing the safety and data-quality benefits of a modernised register.
Mr Hyde said the range of views showed why any eventual framework needed to reflect the very different circumstances across Australian aviation.
‘These submissions show there is no single aviation industry when it comes to the economic impact of regulation,’ he said. ‘A regional airline understandably looks at this differently to a volunteer aero club, a flying school, a private owner or a gliding organisation. But underneath those differences there is considerable common ground: CASA needs to demonstrate what the scheme actually costs, avoid unnecessary duplication, keep administration simple and ensure another apparently modest charge does not simply become the starting point for continuing fee increases.’
RFACA has called for the forthcoming Cost Recovery Implementation Statement and exposure draft legislation to transparently demonstrate the actual ongoing cost of administering the scheme, the basis for any levy, and why lower-cost alternatives could not achieve the same data and safety objectives.
‘The next consultation needs to answer the question that remains unresolved: what are operators actually paying for, why does it cost approximately $1.08 million every year, and is an annual levy the lowest-cost reasonable way of achieving the objective?’ Mr Hyde said.
‘For RFACA, the priority is ensuring grassroots aviation, in particular aero clubs, flying schools, and private operators that provide the entry point into our industry, is not disproportionately burdened simply because light aircraft make up most of the Australian fleet. RFACA will continue engaging constructively with CASA and Government, but we reserve our position on the final scheme until that evidence and the actual cost-recovery arrangements are available.’