AOC, ATO or AMO: which certificate does your aviation business need?

Three certificates, three activities

Uganda’s 2022 civil aviation regulations separate three kinds of organisation that people often group together. Each has its own statutory instrument and its own certificate, issued by the Uganda Civil Aviation Authority (UCAA):

• AOC: the Air Operator Certificate, for organisations that fly commercial air transport.
• ATO: the Approved Training Organisation certificate, for organisations that train aviation personnel.
• AMO: the Approved Maintenance Organisation certificate, for organisations that maintain aircraft.

The quickest way to tell them apart is to ask what the organisation actually does: fly for hire, train, or maintain.

Side-by-side comparison

	AOC	ATO	AMO
Regulations	S.I. 73 of 2022, Air Operator Certification and Administration	S.I. 79 of 2022, Approved Training Organisations	S.I. 78 of 2022, Approved Maintenance Organisations
Core rule	No commercial air transport without a valid AOC (reg 4)	No training organisation without an ATO certificate and training specifications (reg 4)	No maintenance organisation without an AMO certificate (reg 4)
What it certifies	An operator’s organisation, control of flight operations, training and maintenance arrangements	Training that leads to a licence, rating, authorisation or approval, and certain operator training	Maintenance of aircraft, engines, propellers and associated parts
Key UCAA guidance	CAA-AC-OPS001	Confirm with UCAA	Listed on the UCAA Airworthiness page

The AOC

An operator must not engage in commercial air transport unless it holds a valid AOC (S.I. 73 of 2022, regulation 4(1)). To obtain and keep an AOC, the operator has to show that its organisation, its control and supervision of flight operations, its training programme and its maintenance arrangements are adequate for the kind of operation it runs (regulation 4(3)).

Certification follows five phases set out in UCAA advisory circular CAA-AC-OPS001, and an Air Service Licence is needed before the AOC can be granted (CAA-AC-OPS001, §3.0 and §4.0.2). Our AOC certification guide walks through each phase.

The ATO

A training organisation needs an ATO certificate and training specifications (S.I. 79 of 2022, regulation 4(1)). UCAA approves ATOs that provide training leading to the issue of a licence, rating, authorisation or approval, as well as certain training that operators and maintenance organisations need (regulation 4(2)).

For pilots this matters directly. Since S.I. 2024 No. 105, approved training for flight crew, remote flight crew and air traffic controllers must be conducted within an ATO (regulation 24(2) of the amended Personnel Licensing Regulations).

There are exclusions. The requirement does not apply to an AOC or AMO holder training its own personnel under its own regulations, or to certain operators with an approved training programme in their operations manual (S.I. 79 of 2022, regulation 4(1)). If you are unsure whether your training activity falls inside or outside the rule, confirm with UCAA before you start.

The AMO

A person may not operate a maintenance organisation without an AMO certificate (S.I. 78 of 2022, regulation 4(1)). The approval consists of the certificate plus specific operating provisions containing its terms and conditions (regulation 4(2)).

The AMO Regulations cover the approval of organisations that maintain aircraft, engines, propellers and associated parts, wherever those organisations are located, and apply to anyone operating or maintaining a Uganda-registered aircraft, wherever they are (regulation 2). UCAA publishes separate advisory circulars for domestic and foreign AMOs on its Airworthiness page.

How the three connect

An airline does not have to be its own maintenance organisation. UCAA’s AOC guidance asks for a maintenance control manual that sets out the working arrangements between the operator and its AMO (CAA-AC-OPS001, §5.0.13). The manual is needed whether the operator plans to seek its own AMO approval or to contract maintenance out to an AMO (CAA-AC-OPS001, §7.0.8).

Aircraft registration sits alongside all three. When you apply to register an aircraft, UCAA asks you to show the availability of a UCAA-approved maintenance organisation with capability on that type (UCAA advisory circular CAA-AC-AWS001, §3.1.4). See aircraft registration in Uganda.

Which do you need?

If you plan to…	You are likely to need
Run a charter or scheduled airline	Air Service Licence and AOC, plus access to an AMO
Open a flight school	ATO certificate
Train pilots and also fly paying passengers	Both an ATO certificate and an AOC
Run a maintenance hangar or component workshop	AMO certificate
Fly complex (Category C) drone operations	UAS Operator Certificate and a remote pilot licence, under S.I. 96 of 2022

Treat this table as a starting point. The exact approvals depend on your operation, so confirm your plan with UCAA.

Validity and fees

We do not publish AOC, ATO or AMO validity periods or fees, because we have not verified them against the current official text. Confirm them with UCAA.

Common mistakes

• Assuming one certificate covers everything. An AOC does not make you an ATO or an AMO.
• Training before the ATO certificate is issued. Training that is not conducted within an ATO may not count towards a licence.
• Choosing an AMO without checking its scope. Confirm the AMO is approved for your aircraft type.
• Treating drones like aeroplanes. Unmanned operations have their own regulations and certificates.

What Ariguma can help with

Ariguma Aviation Consultants provides aviation consultancy and certification support to organisations working out which approvals they need and how to prepare for them. We can help you map your planned activities to the right regulations and organise your documentation. Approvals are granted by UCAA alone. Contact us to discuss your plans.