Aviation

Air Navigation Order 2016

Category: Aviation regulation · Reviewed by the Apex broking team · Last reviewed 2026-08-22 · ~5 min read

In short: The Air Navigation Order 2016 (SI 2016 No. 765) is the principal piece of UK secondary legislation governing civil aviation. It remains in force and covers registration and marking, airworthiness, operations, aircrew licensing, air traffic services, aerodromes, documents and records, and enforcement. It is not, however, where the compulsory insurance requirement for aircraft operators is found — that sits in separate instruments, which is a distinction operators and their brokers need to get right.

Category: Aviation regulation
Also known as: ANO 2016, the ANO, SI 2016/765
Related concepts: aviation insurance, aviation third party liability, air operator certificate insurance

What the Order is

The Air Navigation Order 2016 consolidated and replaced earlier air navigation orders and is the main body of UK civil aviation secondary legislation. It is organised into parts dealing with interpretation and the categorisation of operations, the application of the Order, registration and marking of aircraft, airworthiness and certification, operations, aircrew licensing and medical requirements, air traffic services, aerodromes and lighting and obstacles, documents and records, prohibited behaviour and enforcement, revocations and transitional arrangements, and review.

For an operator, the Order is the source of most of the day-to-day legal furniture: what has to be on the register, what certificates and licences must be held and produced, what records must be kept and for how long, and which acts are offences. Breaches of the Order are relevant to insurers because most aviation policies condition cover on the aircraft being airworthy, properly certificated and flown by a qualified pilot within the terms of the Order.

Where the insurance requirement actually comes from

The compulsory insurance obligation for air carriers and aircraft operators is not in the ANO. It is in assimilated Regulation (EC) No 785/2004 on insurance requirements for air carriers and aircraft operators, which continues to apply in UK law, and it is enforced domestically by the Civil Aviation (Insurance) Regulations 2005 (SI 2005 No. 1089). Those regulations require operators to maintain insurance meeting minimum levels for liability to passengers, baggage, cargo and third parties, and give the enforcement machinery.

This matters when someone asks for evidence of compliance. A certificate that says an aircraft is insured “in accordance with the ANO” is answering the wrong question; the reference point is Regulation 785/2004 and the 2005 Regulations.

Minimum insurance levels

Minimum cover is expressed in Special Drawing Rights. For liability in respect of passengers, the minimum is 250,000 SDRs per passenger, although a lower minimum of at least 100,000 SDRs may be set for non-commercial operations by aircraft below 2,700 kg maximum take-off mass. For baggage the minimum is 1,288 SDRs per passenger in commercial operations, and for cargo 22 SDRs per kilogram in commercial operations.

Third-party liability minimums are banded by maximum take-off mass, rising from 0.75 million SDRs for aircraft below 500 kg, through 1.5 million (below 1,000 kg), 3 million (below 2,700 kg), 7 million (below 6,000 kg), 18 million (below 12,000 kg), 80 million (below 25,000 kg), 150 million (below 50,000 kg), 300 million (below 200,000 kg) and 500 million (below 500,000 kg), to 700 million SDRs at 500,000 kg and above. Where per-accident cover for war and terrorism risks is unavailable, the obligation may be satisfied by insuring those risks on an aggregate basis.

Unmanned aircraft

Drone and other unmanned aircraft operations are governed principally by UK Regulation (EU) 2019/947, the UAS Implementing Regulation, and UK Regulation (EU) 2019/945, the UAS Delegated Regulation, sitting under UK Regulation (EU) 2018/1139. The ANO continues to set the broader civil aviation requirements alongside them, but the operational categories, competency requirements and operator registration for unmanned aircraft come from the UAS regulations rather than from the Order.

The insurance position for unmanned aircraft follows the same architecture as for manned aircraft: the obligation derives from Regulation 785/2004 rather than from the ANO, and operators should check where their aircraft falls in the mass bands rather than assume that a small aircraft escapes the requirement.

What this means for buying cover

Three practical points follow. First, compliance with the minimum levels is a floor, and for commercial operations exposed to third-party bodily injury and property damage the market limits normally purchased are well above the statutory minimum. Second, because minimums are expressed in SDRs, a sterling limit needs to be tested against the current conversion, particularly for aircraft sitting close to a band boundary. Third, most aviation wordings incorporate regulatory compliance into the cover, so a lapsed certificate of airworthiness, an out-of-date licence or an operation outside the terms of the Order can put a claim in issue quite apart from any regulatory consequence.

Operators that lease aircraft, carry passengers for reward, or operate under an air operator certificate will usually also face contractual insurance requirements from lessors, financiers and airport operators that exceed the statutory position.

Why it matters

The ANO is a safety and licensing instrument; Regulation 785/2004 and the 2005 Regulations are the insurance instrument. Confusing the two is the most common error we see in aviation insurance correspondence, and it produces certificates and warranties that do not evidence what a counterparty actually needs. Getting the reference right is the cheapest part of an aviation placement.

Frequently asked questions

Is the Air Navigation Order 2016 still in force?

Yes. The Air Navigation Order 2016 (SI 2016 No. 765) remains the principal UK civil aviation secondary legislation, covering registration, airworthiness, operations, aircrew, air traffic services, aerodromes, records and enforcement, as amended from time to time.

Does the Air Navigation Order require aircraft insurance?

The compulsory insurance requirement for air carriers and aircraft operators comes from assimilated Regulation (EC) No 785/2004, enforced in the UK by the Civil Aviation (Insurance) Regulations 2005. The ANO governs safety, licensing and operational requirements rather than the insurance minimums themselves.

What are the minimum aviation insurance levels?

For passengers, 250,000 SDRs per passenger, with a possible lower minimum of at least 100,000 SDRs for non-commercial operations below 2,700 kg. Baggage is 1,288 SDRs per passenger and cargo 22 SDRs per kilogram in commercial operations. Third-party minimums are banded by maximum take-off mass from 0.75 million to 700 million SDRs.

Which rules apply to drones in the UK?

Unmanned aircraft operations are governed mainly by UK Regulation (EU) 2019/947 and UK Regulation (EU) 2019/945, under UK Regulation (EU) 2018/1139, with the Air Navigation Order 2016 continuing to set the wider civil aviation requirements. Insurance obligations follow Regulation 785/2004 in the same way as for manned aircraft.

Related entries

This entry is part of the Apex Insurance Wiki. It states the position as at August 2026. Last reviewed 2026-08-22. Next review: 2027-02-22. It is general insurance information, not legal advice, and not regulated advice on a specific policy.

Aviation limits are banded. Yours should be checked against the band.

Statutory minimums, lessor requirements and market practice rarely give the same answer. Bristol-based, FCA-regulated, wordings first.

Call 0117 325 0027 info@apexinsurancebrokers.co.uk

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority (FRN 724952). This page is general information, not advice on a specific policy.

Want a broker to look at your commercial cover?

If you have your renewal pack, Statement of Fact or schedule, send it over and we’ll come back with options — no forms to fill in. Arranging cover for the first time? That works too. Or call 0117 325 0027.

Start a commercial quote →

Larger or multi-site risk? We’ll come and see you.