GCBA
GCBA-06 · v1.0 · Public Draft

Charter Broker Due Diligence

Charter broker due diligence is the documented review a broker performs before recommending or contracting an operator: certification, insurance, operational scope, safety intelligence and the record kept of that review.

Number
GCBA-06
Version
1.0
Published
2025-01-01
Next review
2026-01-01

Purpose

Define what reasonable care looks like when a charter broker selects an operator, so that clients, operators and regulators can see what was checked, when and on what basis.

Scope

  • • Operator selection for all charter flights arranged by a member.
  • • Aircraft, crew and insurance checks carried out at trip level.
  • • Ongoing monitoring of operators used repeatedly.
  • • The records a member keeps to evidence the review.

Core requirements

  • Adopt a written charter broker due diligence policy stating what is checked, by whom and how often.
  • Verify, before contracting, that the operator holds a valid Air Operator Certificate (or national equivalent) covering the aircraft type, the flight category and the route.
  • Confirm the operator, not the broker, exercises operational control of the flight.
  • Verify hull and third-party liability insurance limits, policy validity dates and any passenger-liability endorsement required by the client.
  • Check the specific aircraft registration is listed on the operator's certificate or fleet approval.
  • Confirm crew qualification and currency claims come from the operator in writing, not from an intermediary.
  • Screen the operator and counterparties against applicable sanctions lists before payment.
  • Consider recognised third-party safety intelligence where the flight profile, passenger group or destination warrants it.
  • Re-run the review at a defined interval for repeat operators, and immediately after any material event.
  • Record the review at trip level so it can be reconstructed after the flight.

Examples of acceptable practice

  • A documented policy that references recognised safety data sources and states how they are weighed.
  • Refusing or escalating a booking when certification, insurance or aircraft listing cannot be evidenced.
  • Telling a client plainly which checks were performed and which were not.
  • Storing operator documents with expiry alerts so lapses surface before the next booking.

Examples of problematic practice

  • Public claims of 'safety rated' or 'GCBA approved' operators without a verifiable basis.
  • Relying on a screenshot, a broker-to-broker assurance or a prior booking as proof of current certification.
  • Checking certification only after the client has paid.
  • Presenting a third-party audit registration as though it were the broker's own review.
  • Keeping no trip-level record, so the review cannot be evidenced if the flight is later questioned.

Jurisdiction notes

  • GCBA does not conduct operator safety audits and does not certify operators.
  • In the United States, air charter brokers are subject to DOT rules on disclosure and unfair or deceptive practices; due diligence records support those disclosures.
  • In the EU and UK, the operating carrier must hold a valid Air Operator Certificate and matching operating licence; broker checks do not substitute for that.
  • Insurance minimums are set by regulation in many jurisdictions and by contract in others — check both.

What charter broker due diligence actually is

A charter broker arranges flights; it does not fly them. Operational control — the aircraft, the crew, the decision to depart — sits with the licensed air carrier. Due diligence is the work a broker does to satisfy itself, and to be able to demonstrate to a client, that the carrier it is placing the flight with is entitled and equipped to perform it.

That makes due diligence an evidentiary discipline rather than a safety judgement. The broker is not certifying the operator. It is recording that certification, insurance, aircraft listing and scope were checked against primary sources at a known point in time, and that anything unresolved was escalated rather than absorbed.

The pre-flight due diligence checklist

Members are expected to be able to answer each of the following, in writing, before a charter agreement is signed:

  • Which legal entity is the operating carrier, and what certificate does it hold?
  • Does that certificate cover this aircraft type, this flight category and this route?
  • Is the specific tail number on the operator's approved fleet list?
  • Are hull and liability policies in force for the dates of travel, at limits the client has been told about?
  • Who holds operational control, and has that been disclosed to the client in writing?
  • Has the operator, and any payment counterparty, been sanctions-screened?
  • Does the flight profile — passengers, destination, night or over-water sectors — justify additional safety intelligence?
  • Where is the record of all of the above stored?

Proportionality: not every flight needs the same file

Due diligence is proportionate, not uniform. A repeat domestic sector with a long-standing operator whose documents are current on file does not require the same depth as a first-time placement with an unfamiliar operator into a high-risk region, or a flight carrying an unaccompanied minor or a medical passenger.

What must never be proportionate is the record. Whether the review took four minutes or four hours, the file should show what was checked and when. A thin file is defensible; an absent one is not.

Where broker due diligence commonly fails

The recurring failures reported to the Association are not exotic. Documents are collected once and never refreshed, so an insurance certificate quietly expires between bookings. A tail number is substituted late and nobody re-checks whether the replacement aircraft sits on the same certificate. A sub-charter chain is assembled between brokers, and each participant assumes another performed the review.

The countermeasure in each case is structural rather than diligent: expiry tracking on operator documents, a mandatory re-check on aircraft substitution, and a rule that a broker never relies on another broker's diligence without seeing the underlying evidence.

What to tell the client

Clients are entitled to know what the broker verified and what it did not. Members should state the operating carrier by name, confirm that operational control rests with that carrier, describe the checks performed in plain language, and avoid any formulation implying that the broker has rated, approved or guaranteed the safety of the flight.

The strongest position a broker can occupy after an incident or a dispute is a truthful, dated, retrievable account of the review it performed. That is the entire purpose of this standard.

Frequently asked questions

What is charter broker due diligence?

It is the documented review an air charter broker performs before placing a flight with an operator — verifying the Air Operator Certificate, aircraft listing, insurance, operational control, sanctions status and any relevant safety intelligence, and keeping a record of what was checked and when.

What should a charter broker check before every flight?

At minimum: the operating carrier's certificate and its scope, that the specific tail number is on the approved fleet list, valid hull and liability insurance for the travel dates, written confirmation that the operator holds operational control, and sanctions screening of the operator and payment counterparty.

Is a broker responsible for flight safety?

No. Operational control and safety of flight rest with the licensed air carrier. The broker's responsibility is to exercise and evidence reasonable care in selecting and disclosing that carrier, and not to make safety claims it cannot substantiate.

How long should due diligence records be kept?

Retain operator files and trip-level records for at least the limitation period applicable to charter contracts in the relevant jurisdiction, and longer where insurance, aviation or AML rules require it. Records should remain retrievable after the flight, not only during it.

Does GCBA approve or audit operators?

No. GCBA is an industry association. It publishes standards for broker conduct and does not certify aircraft, audit operators or issue safety ratings. Members must not describe operators as GCBA-approved.

How often should due diligence be repeated for a regular operator?

Set a fixed interval in the written policy — commonly annually for the operator file, with document-expiry triggers — and re-run the review immediately after any material change, such as an aircraft substitution, a change of certificate holder or an adverse event.

Related knowledge

Change history

VersionDateNote
1.02025-01-01Initial public draft.
This standard is educational and does not constitute legal advice. Members must comply with applicable law and regulation in every jurisdiction in which they operate.
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Method, obligations and practical guidance

Reading GCBA-06 in the wider framework.

How this standard was drafted

Charter Broker Due Diligence was prepared by a drafting group convened by the Advisory Board and opened for public consultation before adoption. Every material comment received during the consultation window was logged, considered and disposed of on the record. The version and status shown at the top of this page reflect the outcome of that process; earlier versions, where they exist, remain accessible through the changelog.

A standard is not a checklist. It is a statement of what the Association considers professional practice, expressed in language a member can operationalise, an operator can rely on and a client can read. The requirements above are drafted in the imperative for that reason: they describe conduct, not paperwork.

“A standard exists to make the invisible parts of a transaction legible — to the client who commissions it, the operator who performs it and the regulator who oversees it.”
GCBA Standards Charter

Member obligations

Members accept the Code of Professional Conduct on joining and, by extension, agree to operate consistently with the standards framework of which this document forms part. Where this standard requires evidence, members are expected to retain that evidence in a form that can be produced on request during periodic review.

Where a jurisdiction imposes an obligation that goes beyond this standard, the jurisdictional rule prevails. Where a jurisdiction is silent, this standard describes the Association's expectation. Where the two conflict, members are expected to comply with law and to record the tension in a note that can be shared during the next consultation cycle.

Practical guidance for implementation

Most members will operationalise this standard by adjusting three artefacts: the client-facing engagement or quotation document, the internal verification or operating checklist, and the post-engagement record. Reviewing those three documents against the requirements above is a reliable first pass. Where the standard names an evidence expectation, the record should show not only that the step was completed but how it was completed and by whom.

For contested or borderline cases, the Association issues non-binding interpretive notes on request. Notes are anonymised before publication and are treated as reference material for the next scheduled review of this standard.

How this standard connects to the rest of the framework

No standard operates alone. Conduct, disclosure, verification, contracts, payments, safety, privacy, marketing and training are interdependent: a shortfall in one standard often manifests as a failure recorded against another. Members implementing this document are encouraged to read the related knowledge articles linked above and to review the full framework index to place these requirements in context.

Comments, dissenting views and proposed revisions to this standard are welcomed at any time and considered formally at the next scheduled review. The open consultations page lists all drafts currently open for structured feedback.