Author: Nuno Sardinha da Mata, Senior Partner
Macau is taking off—legally speaking. With the enactment of Law No. 4/2025, a new and comprehensive legal framework is now governing civil aviation activities across the SAR since February 1, 2026.
Whether you’re an established airline, a drone operator, an airport concessionaire, or a startup looking to enter the aviation market, these changes matter.
The law also established the RANM (Regulation of Air Navigation of Macau), published as complementary legislation by the Secretary of Transport and Public Works through the Dispatch number 16/2026, which is now a fundamental piece of the regulation of civil aviation in Macau.
- Clear Licensing and Oversight Requirements Operators of passenger air services will now need dual authorization:
- A certificate of air operator from the Civil Aviation Authority of Macau (AACM)
- A license of activity issued by the Chief Executive, with limits on the number of licenses granted.
- Stronger Entry Standards Applicants must demonstrate:
- Financial capacity to sustain operations without revenue for up to three months
- Technical capability and adequate infrastructure
- Personal and corporate reputation checks—including for directors and shareholders with 5% or more equity.
- Regulation of Drones (Unmanned Aircraft) Drones are now classified by risk level, with corresponding operational requirements. Most categories will require AACM authorization and civil liability insurance.
- New Corporate Governance Obligations Licensed aviation companies are subject to restrictions on share transfers and must submit:
- Annual financial reports
- A 5-year business plan every five years
- Immediate notice of relevant legal, financial, or organizational developments
- Real Penalties Violations may lead to:
- Fines of up to MOP 1,000,000
- Suspension or revocation of licenses
- Public disclosure of judgments
- Even judicial dissolution in extreme cases of repeated misconduct
Existing operators will need to revalidate their compliance, update corporate documents, and prepare for new reporting cycles. The law also includes transition provisions for current concessionaires and certified operators.
New entrants—especially international investors and service providers—will benefit from legal certainty but face a higher regulatory threshold.
If you’re operating in Macau’s aviation sector—or planning to—now’s the time to chart your course with legal clarity. Reach out to our team and let us help you fly safely through the new regulatory skies.
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