China’s Civil Aviation Administration of China (CAAC) has implemented a significant regulatory change affecting all business aviation operators flying into or over China. Under updated charging management regulations for basic air traffic control (ATC) services, advance payment or a registered Letter of Guarantee is now a prerequisite for permit approval.

This requirement takes effect April 1, 2026 and is directly embedded in the CAAC landing and overflight permit process.

What Has Changed

Under the new regulation:

• ATC charges now formally include approach control fees and air route navigation fees
• Payment must be completed before the flight enters China, or
• A valid Letter of Guarantee must be registered in the CAAC system

Previously, ATC charges were billed after the flight, with payment made directly to the CAAC Settlement Center. That post flight settlement model has been eliminated.

Flights that do not meet the advance payment or Letter of Guarantee requirement will not be accepted for landing or overflight permit application and will not be allowed to enter China.

Universal Aviation China Perspective

According to Ricky Fang, Assistant General Manager, Universal Aviation China, this change represents a structural shift in how China permits are approved, not a routine billing update.

“This is no longer a post flight accounting matter. ATC charge settlement is now a prerequisite for permit approval,” Fang said. “If advance payment is not completed, or a valid Letter of Guarantee is not registered in the CAAC system, the landing or overflight permit will not be accepted. In practical terms, that means the flight will not be allowed to enter China.”

Fang emphasized that operators must treat ATC charge settlement as a critical path item in flight planning.

“Operators need to decide early whether they will manage these payments themselves or appoint a handler to do so. Waiting until permit submission will be too late under the new process.”

Direct Impact on Permit Applications

The new payment requirement is now formally incorporated into the CAAC permit approval process for:

• Landing permits
• Overflight permits

Permit applications submitted without confirmed advance payment or a registered Letter of Guarantee will be rejected.

Payment Options

Operators now have two compliance paths.

Option 1: Universal Aviation China Manages ATC Charges

If Universal Aviation China is your designated handling agent and manages ATC payments on your behalf:

• CAAC is currently unable to provide a VAT compliant tax invoice (fapiao) for ATC charges
• This results in an approximate 25 percent increase in tax cost for this specific line item
• Revised charges will appear on future invoices until compliant invoicing becomes available
• Updates will be provided once CAAC confirms a resolution timeline

Option 2: Operator Handles Payments Directly

Operators choosing to manage ATC payments themselves must use one of the following advance payment schemes:

1. Advance payment for a single trip

2. Advance deposit covering multiple future flights

Important notes:

• All advance payments are recorded and settled in RMB
• Any unused balance may be carried forward and applied to future flights
• If operations to China are terminated, refunds can only be made to an RMB account

Letter of Guarantee Status

CAAC has not yet confirmed whether a local Chinese entity owned by an overseas operator may sign the CAAC agreement and provide a Letter of Guarantee on behalf of the overseas flight department.

At present, CAAC has advised that only operators themselves or handling agents may be officially registered in the system. Further clarification is pending.

What Operators Should Do Now

• Review planned China operations for April 1, 2026 and beyond
• Decide who will manage ATC charge settlement
• If handling directly, prepare RMB payment capability or Letter of Guarantee arrangements in advance
• Anticipate permit rejection if payment compliance is not confirmed

Bottom Line

Effective April 1, 2026, advance payment of China ATC charges or a valid Letter of Guarantee is mandatory for all landing and overflight permits issued by CAAC. This is a hard compliance requirement. Operators that fail to meet it will not be permitted to enter Chinese airspace.

Early coordination with handlers, finance teams, and flight planning staff is essential to avoid permit denial and operational disruption.