What counts as a direct cost on a cost-sharing flight?

Only four things count as direct costs on a UK cost-sharing flight: fuel, oil, airfield charges and aircraft rental fees at the current market rate. Everything else, including insurance, maintenance, hangarage and club membership, must be paid by the pilot with no contribution from passengers.

That list has been exhaustive since the rules changed on 1 October 2025. This guide walks through each item, what the law leaves out, and the handful of costs where the answer is genuinely unclear.

The statutory list

The definition now sits in both UK Regulation (EU) 965/2012 (Article 2(12), inserted by SI 2025/878, reg 11) and the Air Navigation Order 2016, Schedule 1. The wording is the same in both:

"'direct costs' means the costs only directly incurred for a flight and include only: (a) fuel; (b) oil; (c) airfield charges; and (d) aircraft rental fees at current market rate"

Two words do a lot of work here. "Only directly incurred" means the cost has to arise because of this particular flight. "Include only" means the list is closed: if a cost isn't one of those four, passengers can't contribute to it.

NCO.GEN.102(b) makes the other side of that explicit: "All costs other than direct costs must be paid by the pilot with no contribution from the passengers."

Fuel and oil

The fuel and oil you burn on the flight. If you hire wet, fuel is already in the hourly rate, so don't add it again. If you hire dry or fly your own aircraft, use what you actually uplift or burn for the trip.

Airfield charges

Landing fees are the most obvious example of an airfield charge, although the term "airfield charges" isn't defined any further, which matters for some of the grey areas below.

Aircraft rental at current market rate

If you hire the aircraft, the rental fee counts, but only up to the market rate. CAA guidance defines market rate as "the average rental price of the same type of aircraft in the same geographic area on the particular date of the flight" (GM1 NCO.GEN.102(c)(b); CAP 1590, para 37).

In practice, if your club charges a typical rate for a PA-28 in your area, you're fine. If you've somehow ended up paying well above the going rate, the excess is not shareable. Our aircraft cost pages give indicative UK hire ranges for common types.

Annual costs are out

CAP 1590, para 29, is clear: "'Annual costs' are the cost of keeping, maintaining, insuring and operating the aircraft over a period of one calendar year. These costs are required to be paid by the pilot/operator of the aircraft with no contribution from passengers."

The legislation's own definition of "annual cost" (ANO 2016, Schedule 1) is "the cost (excluding any element of profit) of keeping, maintaining and operating the aircraft over the period of one year", and CAP 1590's para 38 uses the same three words. Neither mentions insuring, but insurance can't be shared either way, because it isn't one of the four direct costs.

The CAA's cost sharing page adds that this includes "items like club membership fees for renters".

So passengers can't contribute towards:

• insurance
• maintenance, servicing and annuals
• hangarage or tie-down fees
• club or group membership fees
• depreciation or engine reserves (excluded because they aren't on the list, although the rules don't name them specifically)

The CAA considered widening the list during consultation and declined: "The CAA does not intend to expand the acceptable costs to include annual costs" (CAP 2391).

Owned aircraft

Joint owners and groups

If you fly a group or jointly owned aircraft, the hourly rate a joint owner normally pays for using it counts as a direct cost. GM1 NCO.GEN.102(c), point (c), describes it as "the hourly rate, normally payable by a joint owner, for use of their aircraft", with a cap: it "may be no more than the average market rental price." CAP 1590 (para 30) says the same, except that the rate "should be no more" than the average market rental price.

So if your group charges members £150 an hour wet, that's the figure you share, as long as it isn't above the local market rental for that type. You can't uplift it to recover your share of the group's fixed monthly costs.

Sole owners

This is the unclear case. CAA guidance addresses joint owners' hourly rates, but neither the legislation nor the guidance says anything about a sole owner charging a notional rental fee for their own aircraft. A sole owner doesn't pay anyone rent, so there is no rental fee in the ordinary sense.

The cautious reading is that a sole owner can share only fuel, oil and airfield charges, and carries everything else. If you want to do more than that, get advice before you rely on it, and keep a clear record of how you worked out the figure.

Grey areas

The definition doesn't spell out what "airfield charges" covers, and some flight-related charges don't obviously fit any of the four headings.

• Parking fees at the destination. Parking charged by the airfield is arguably an airfield charge, but the term isn't defined and some commentary suggests parking is excluded. Treat it as unclear.
• Approach or ATC charges levied by the airfield. These may fall under airfield charges, but the rules don't say so.
• Overnight hangarage charged by a destination airfield. Hangarage is an annual cost, and whether a one-off charge is an "airfield charge" is not settled. Pay it yourself.
• En-route or other navigation charges. These aren't listed, and on a literal reading of the closed list they are excluded.

The cautious approach with any of these is to pay them yourself. It costs you a little, and it removes any argument that passengers paid for something outside the definition.

Can share, can't share, unclear

Turning direct costs into a per-person figure

Once you've added up the direct costs, the passengers' share is capped at that total divided equally by everyone on board, pilot included (NCO.GEN.102(c)). CAP 1590 (guidance, para 27) adds that the pilot must pay at least that equal share, and GM1 NCO.GEN.102(c) confirms the pilot can pay more. Our cost-sharing calculator does the division for you, and who pays what works through several real-world examples.

A sensible habit is to note how you reached the figure for each flight: the hire rate, the fuel uplift, the landing fee receipts. Split My Flight keeps a compliance document for every flight alongside each passenger's signed declaration, so if anyone asks later you have the record in one place.

For the wider rules around cost sharing, see CAP 1590 and the cost sharing rules explained or the regulations overview.