NCO.GEN.102(g) and (h): passenger declaration records

NCO.GEN.102(g) and (h) require a record for each passenger, completed before the flight, showing they were told the flight doesn't meet CAT safety standards and that they accepted this by signing a declaration. The operator keeps the record for six months from the date of the flight and produces it when an Authorised Person asks.

The text

NCO.GEN.102(g) and (h):

(g) For each passenger, a record must be made attesting to:

(1) their having been clearly advised that the flight does not meet the same safety standards as a CAT flight; and

(2) their acceptance of this fact as indicated by their signed declaration to this effect.

(h) The records referred to in (g) above must be:

(1) completed prior to the flight;

(2) retained by the operator of the flight for a period of 6 months from the date of the flight; and

(3) produced by the operator of the flight when requested by a person who is an Authorised Person within the meaning given in Schedule 1 to the Air Navigation Order 2016.

ANO 2016 art. 13(2)(g) and (h) are the same in substance. They refer to "a CAT or PT flight" and to "an Authorised Person", which the ANO defines itself.

AMC1 NCO.GEN.102(g), in force since 1 October 2025:

(a) The method of recording the safety standards being identified and accepted by the passenger(s) can be such as in the format provided by the CAA, or such method available to the pilot, but which should record as a minimum the following:

(1) Date of Flight;

(2) Aircraft Type and Registration;

(3) Departure and Arrival information;

(4) Passenger information on the differences and associated risks between Commercial Air Transport (CAT) and flights under this regulation; and

(5) Passenger Name(s), contact details and passenger signature or other means of indicating acceptance of cost sharing flight.

(b) Recording and acceptance of safety standards is not required for passengers who hold or have held a pilot’s licence proved to the satisfaction of the pilot-in-command of the cost sharing flight.

(c) New records do not need to be made for passengers on repeat flights who have flown with the same pilot on a cost sharing flight within the last 6 calendar months, provided that the original record is retained, updated to include the repeat flight details and retained for a further 6 months from the date of any repeat flight.

(d) Passengers who are required to sign the declaration and consent form and who are under the age of 18, or who otherwise cannot legally or physically do so, should have the risks accepted on their behalf by an individual who has legal authority to make decisions for that person, or by an individual to whom such authority has been delegated for the relevant period.

What it means in practice

An Authorised Person, under ANO Schedule 1, includes "any constable" and "any person authorised by the CAA". CAP 1590 (guidance), para 18, confirms the record "can be a paper or electronic record", and para 19 says the form "must be completed by the Pilot in Command".

Worked example. Sam flies with you on 12 March 2026 and signs a declaration on 10 March. You keep it until at least 12 September 2026. Sam flies with you again on 20 May 2026, within six calendar months, so under AMC1(c) you update the original record with the new flight details instead of making a new one, and keep it until at least 20 November 2026. Another passenger on the same flight who has held a PPL, and shows you evidence, needs no record under AMC1(b).

Grey areas

• "Signed declaration" or "other means". The law says "signed declaration"; AMC1(a)(5) allows "passenger signature or other means of indicating acceptance". What counts as "other means" isn't spelled out. The cautious approach is a record that ties the acceptance clearly to the named passenger, with the date it was given.
• Pilot or operator. Point (h) places retention on "the operator of the flight"; CAP 1590, para 17, says "the pilot/operator". When you hire an aircraft, the cautious approach is to keep the records yourself.
• Consequences. The legislation and CAA guidance cited here don't identify a separate offence for a missing record. What is clear is that the flight would not satisfy NCO.GEN.102, which every cost-shared flight must.

How to comply

• Before each flight, give the safety information described under point (f).
• Record the five AMC1 minimum items for each passenger who needs one, and get their acceptance before departure.
• Keep each record for six months from the flight, or from the latest repeat flight.
• Be able to produce it on request.
• Use the free passenger declaration form on paper, or let Split My Flight collect declarations online and keep the records for you. The passenger declarations guide has the full treatment.