Regulations

What changed on 1 October 2025 for cost sharing

A before and after table of the UK cost sharing rule changes from 1 October 2025, and what they mean in practice for private pilots flying passengers.

Updated · 6 min read

On 1 October 2025 the UK cost sharing rules were rewritten: the pilot must now pay at least an equal share of the direct costs, "direct costs" became a closed list, and every passenger (other than current or former licence holders) must sign a declaration that is kept for six months. Advertising became regulated with seven mandatory items, and permit aircraft and microlights moved onto the same footing as Part-21 aircraft, including the six-person limit.

The changes were made by SI 2025/878 for Part-21 aircraft (inserting NCO.GEN.102 and amending Articles 2 and 6(4a) of UK Regulation (EU) 965/2012) and by SI 2025/850 for non-Part-21 aircraft (amending article 13 of the Air Navigation Order 2016). The supporting AMC and GM came into force the same day. A year on, these are the rules in force, but it's worth knowing what moved if you learned to cost share under the old regime.

Before and after at a glance

Topic Before (to 30 Sep 2025) After (from 1 Oct 2025)
Maximum persons, Part-21 aircraft 6 sharing direct costs 6 including the pilot
Maximum persons, non-Part-21 aircraft 4 under ANO art. 13; 6 under the ORS4 No. 1608 exemption, in the London and Scottish FIRs only 6 under ANO art. 13
Pilot's share, Part-21 Costs "shared by all the occupants … pilot included"; a nominal contribution (for example 1p) was enough Passengers pay no more than 1/N each; the pilot pays at least an equal share and may pay more
Pilot's share, non-Part-21 Pro-rata cap in ANO art. 13(2)(b) Same rule as Part-21
Definition of direct costs ANO: fuel, airfield charges, rental or hire ("including", an open list). 965/2012: not defined Exhaustive: fuel, oil, airfield charges, aircraft rental at current market rate
Costs that aren't direct costs Annual costs excluded by guidance Must be paid by the pilot with no passenger contribution, now in law (NCO.GEN.102(b))
Passenger declaration Not required Required for each passenger, completed before the flight, kept 6 months
Advertising, Part-21 Allowed; disclosures only "recommended" Must be placed by the pilot and include 7 mandatory items
Advertising, non-Part-21 Banned by the ANO except within a flying club (an exemption removed the ban) Allowed, with the same content rules
Private individual, no paid pilot Yes Yes, now set out in NCO.GEN.102(d) and (e)
LAPL(A) passenger rule 10 hours as PIC after licence issue before carrying passengers Removed
Common purpose for the trip Not required Not required (proposed in consultation, then dropped)
Minimum hours for cost sharing None None

Sources: Article 6(4a) of 965/2012 old and new, ANO art. 13 as at 30 September 2025 and current, ORS4 No. 1608, ANO Schedule 1, SI 2025/878, Part-FCL FCL.105.A, CAP 1589, CAP 2391 and the CAA Opinion document.

What it means in practice

You pay your share, properly

This is the biggest change for many pilots. Under the old Part-21 wording, a nominal pilot contribution was enough, so four people could in effect fly a pilot for close to nothing. Now NCO.GEN.102(c) caps each passenger's contribution at "the total direct costs divided equally by the number of persons carried (including the pilot)." With three passengers your share must be at least 25% (CAA Opinion document). CAP 1590 confirms you may choose to pay more than your share (para 27), and in that case passengers pay less.

What the rules don't settle is whether one passenger may pay more than an equal share if another pays less. CAP 2391 says the pilot may not "accept more than such equal contribution", which suggests each passenger is capped at their own equal share. The cautious approach is to cap every passenger at 1/N and absorb any difference yourself. The cost sharing calculator does the arithmetic.

Only four kinds of cost can be shared

Direct costs now "include only" fuel, oil, airfield charges and aircraft rental fees at current market rate. The old ANO wording was an open list. Market rate means "the average rental price of the same type of aircraft in the same geographic area on the particular date of the flight" (CAP 1590, para 37), so you can't inflate the hourly rate. Joint owners may use the hourly rate a joint owner would normally pay, but no more than the average market rental price (GM1 NCO.GEN.102(c); CAP 1590, para 30).

Insurance, maintenance, hangarage and club membership aren't on that list, so they stay with you. Some items aren't named at all, such as en-route navigation charges, and the rules don't say whether a sole owner can charge a notional rental rate. The direct costs guide sets out the cautious reading, and the aircraft cost pages give typical figures by type.

Paperwork before every flight

Before October 2025 there was no legal passenger declaration. Now NCO.GEN.102(g) and (h) require a record for each passenger showing they were clearly advised the flight doesn't meet CAT safety standards and that they accepted this by a signed declaration. It must be completed before the flight, kept for 6 months from the date of the flight and produced if a constable or a person authorised by the CAA asks.

The AMC sets the minimum content: date, aircraft type and registration, departure and arrival, information on the differences and risks compared with CAT, and the passenger's name, contact details and signature. Passengers who hold or have held a pilot's licence don't need one, and a record for a repeat passenger flying with you again within 6 calendar months can be updated rather than redone. Split My Flight sends each passenger the required information, collects their signed declaration online and keeps the record for the retention period. More detail is in the declarations and records guide.

Adverts must carry seven items

If you advertise or promote a flight, you must place the advert yourself (for non-Part-21 aircraft, ANO article 13(3) also allows the operator) and include: a statement that it is a private arrangement not conducted in accordance with CAT safety standards, the start and end locations, the date you are available, your licence type, your medical class or declaration, your total hours, and your hours on type in the previous three months. The legislation applies to any "advertisement or promotion" regardless of medium. Whether a casual post in a closed club group counts is not settled, so the cautious approach is to include all seven items wherever you post. See the advertising guide.

Permit aircraft and microlights caught up

Non-Part-21 pilots gained the most. The four-person ANO limit rose to six, the regional six-seat exemption under ORS4 No. 1608 is no longer needed, and advertising is allowed. Remember that your licence and aircraft may still limit you: LAPL(A) and NPPL(A) holders can carry no more than four people in total, and a microlight is designed for no more than two. The six-person limit guide covers this.

LAPL holders lost a hurdle

The LAPL(A) requirement to log 10 hours as PIC after licence issue before carrying passengers was omitted from 1 October 2025. The normal recency requirement of three take-offs, approaches and landings in the preceding 90 days still applies.

What didn't change

You still fly as a private individual, nobody may be paid to pilot the flight, and passengers still can't contribute to anything that isn't a direct cost. There was no new minimum hours requirement and no "common purpose" test; both were raised in consultation and not adopted (CAP 2391). For the full set of conditions as they now stand, read CAP 1590 and the cost sharing rules explained or the regulations overview.

Frequently asked questions

Is a token 1p contribution from the pilot still allowed?
No. Before October 2025 a nominal contribution was enough on Part-21 aircraft. Now passengers may pay no more than the total direct costs divided equally by everyone on board, so the pilot pays at least an equal share.
Can I now fly six people in a permit aircraft outside the London and Scottish FIRs?
Yes, if the aircraft can carry them and your licence allows it. ANO article 13 now sets a limit of six persons including the pilot, the same as for Part-21 aircraft, with no FIR restriction.
Do declarations from before October 2025 count?
No declaration was required before 1 October 2025. For each flight now, you need a record completed before that flight, kept for 6 months, unless an exemption such as the passenger holding or having held a pilot's licence applies.
Did the changes add a minimum hours requirement?
No. The CAA declined consultation requests for minimum hours, and there is no hours minimum in NCO.GEN.102 or ANO article 13. The LAPL(A) 10-hour rule before carrying passengers was actually removed.

This guide summarises the CAA's published guidance and is not legal advice. Always check the latest version of CAP 1590 before you fly. Compliance remains the responsibility of the pilot in command.