Aviation Act Enforcement

20 September, 2022
2,5 minutes reading time
Blog posts IATA

In late November, all Approved Agents and Known Consignors were informed in writing by the NCTV of, among other things, the requirement for BBLV entities to designate an internal security manager responsible for implementing the security program and resulting security measures. Following this obligation, in late July, the following mailing was sent to clients and associates of SCS Training & Consultancy.


Dear relation,
It emerged last week that the Royal Military Marechaussee (Kmar) is now actively enforcing the requirement announced last year to internally appoint a Security Manager (as a replacement for the

Security Advisor Air Freight) by the Approved Agent (RA) and Known Consignor (KC). Further below is the received clarification on this from the Kmar.
Although an exact deadline for this has not yet been given by the NCTV, the first Recognized Agents have now been assessed as “non-compliant” by the Kmar. After a negative assessment, the condition for compliance with laws and regulations is that within 2 months an internally designated Security Manager must have successfully completed the required training (currently: Security Advisor Air Cargo) and the certificate can be presented. Failure to comply with this condition may result in revocation of Approved Agent or Known Sender status.

Based on the initiated enforcement from Kmar, I can’t help but advise you to take the necessary action immediately and appoint a Security Manager internally and give this person the 3-Day Basic Security Advisor Air Freight Course to be taken and then applied for the mandatory CITO exam. I want to emphasize here, that this is completely unexpected for us and we are “only” the messenger in this. However, the Kmar’s interpretation herein is that e.g. could be inferred from previously sent letters.

The first parties to face active Kmar enforcement are likely to be the Approved Agents who assign a status to secure cargo, such as freight forwarders who, whether or not after conducting (or having conducted) a security screening, list SPX status on the Air Waybill.

If you have any questions regarding this newsletter, please feel free to contact us, but I would especially like to ask you to wait for the letter from the Kmar and then contact them with any questions regarding this subject.

Patrick Shoemaker
Operations Manager


Clarification KMAR dated July 20, 2022:

“On Nov. 15, 2021 (reference: 3655165) and June 1, 2022 (reference: 4027468), all RAs and QCs were informed in writing by the NCTV regarding, among other things, the requirement for a BBLV entity to designate an internal security manager responsible for implementing the security program and resulting security measures. They were also informed about the relevant training required and the transitional measures offered regarding the training to be taken. If you have questions about this, I refer you to the letter from the NCTV dated June 1, 2022.

As of July 1, 2022, we, as the supervisor, started to explicitly monitor compliance with what is mentioned in point 11.2.5 of the Annex of Implementing Regulation (EU) 2015/1998. That is, each BBLV entity should designate a security manager within its own organization as soon as possible. This security manager may be BAL trained until the implementation deadline regarding the “Security Manager Air Cargo and Mail and Supervisor Air Cargo and Mail” trainings has passed. This implementation deadline was also made known in the letter dated June 1, 2022 and expires on June 1, 2023.

All entities will receive another letter explaining this in the near future.”

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