New EU regulations: Ground handling agents will bear more safety responsibilities
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On December 19, 2024, the European Commission adopted and on March 7, 2025, published Delegated Regulation (EU) 2025/20: Requirements for the safe provision of ground services and requirements for organizations providing ground services; and Implementing Regulation (EU) 2025/23: Regulatory requirements for ground services and organizations providing them.
I. Main contents of the new regulations

The core content of the delegated regulation (EU) 2025/20 is to regulate the safe provision of ground services and the responsibilities of related organizations within the EU to ensure aviation safety and promote unified standards. It applies to organizations that provide ground services at airports, including independent ground handling organizations, airport operators that provide ground services, and airlines' own ground services. Applicable ground services include passenger handling, baggage handling, aircraft services, aircraft turnaround activities, cargo and mail handling, etc., but do not cover activities that have been regulated by other regulations, such as aircraft guidance, flight dispatch tasks, loading control tasks, ground supervision, aircraft fuel handling, etc. The specific content includes: the definition and classification of ground handling organizations, the responsibilities and management requirements of ground handling organizations, the operating procedures requirements for ground services, training requirements, ground support equipment (GSE) requirements, declarations and transitional clauses, and the entry into force and application of regulations.
The core content of the implementing regulation (EU) 2025/23 is the applicable rules on the regulatory requirements for ground services and their providers to ensure the consistency and effectiveness of ground service supervision within the EU. The core goal of the regulation is to establish a regulatory framework for ground handling services and providing institutions by the competent authorities of the member states, ensure the safety and compliance of ground handling services, coordinate multi-national regulatory cooperation, and improve the level of aviation safety. It is applicable to the supervision of organizations providing ground handling services (including independent ground handling organizations, airport operators, airlines' self-operated ground handling, etc.) within the EU, covering compliance inspections of ground handling services, allocation of responsibilities by competent authorities, information sharing and law enforcement measures.
II. Main impact of the new regulations
Delegated Regulation (EU) 2025/20 and Implementing Regulation (EU) 2025/23, especially the new regulatory requirements proposed by Implementing Regulation (EU) 2025/23, ground handling agents will formally assume the safety responsibility for ground handling services, which will ease the relevant responsibilities of operators when operating at airports within the EU.
In other words, through the cooperation between ground handling agents, airports and operators, ensure that all parties understand the new interface between the various entities and clarify the division of responsibilities. The main safety responsibilities previously borne by operators will be redistributed between operators, ground handling agents and airports.
In addition, the new regulations are also committed to solving the problem of repeated audits of ground handling agents. EASA and national competent authorities will work together to establish an effective cooperative supervision mechanism, including establishing unified inspection standards, developing unified training courses for inspectors, and establishing safety data models and databases to facilitate risk-based supervision in this area. The new regulations also provide unified training requirements for different ground handling positions.
Delegated Regulation (EU) 2025/20 explicitly excludes ground handling activities that are already regulated by other laws, including weight balancing regulated by (EU) 965/2012. Other excluded ground handling activities include aircraft guidance, dispatch release, ground supervision, fuel handling, and maintenance-related ground handling activities. I am more familiar with the provisions related to weight and balance in (EU) 965/2012. They are all technical requirements related to aircraft weight and balance, similar to the requirements for weight and balance in our Part 121. I have not seen any description of the provisions in (EU) 965/2012 regarding the rights and responsibilities between ground handling agents and operators.
3. Thoughts on the new regulations for domestic load balancing agent services
Although the EU excludes load balancing, aircraft guidance, dispatch release and maintenance-related ground handling activities, the EU's division of responsibilities between operators and ground service agents through supervision, and the establishment of a unified ground service agent inspection system and job competency training standards, still brings new inspiration to the current responsibility relationship between domestic load balancing agents and airlines.
1. Implementation of the main body's safety responsibility
Most of the current load balancing unsafe incidents occurring in China and around the world are caused by errors of load balancing agents. Who will bear the responsibility if the load balancing agent makes a mistake? We have discussed this issue in "Observing the Load and Balance Bureau Supervision (I)":
CCAR121-R8 states that "the certificate holder shall prepare a loading manifest and be responsible for its accuracy", and AC-121-FS-135 Appendix VII also states the safety responsibility of the load and balance agent work: "The operator may entrust the specific work of load and balance to the agent, but the supervision responsibility for safety risks still belongs to the operator, and the supervision mechanism for agents should be improved."
Although the description of relevant responsibilities in Part 121 and the advisory circular is clear enough, there are also various difficulties in the actual implementation of operators, such as the difficulty in controlling the initial training of agent personnel, the difficulty in real-time supervision of the agent's work process, the uniqueness of airport agents, and the airport agent subcontracting the load and balance work to a third party.
Some airline colleagues have proposed that the responsibilities of airlines and agents can be divided through an agreement, but under the current regulatory conditions, it is unlikely to be realized.
At present, the domestic situation is that the airlines, agents, and both sides are punished for daily supervision of agents and error handling of agents. From 121 to the advisory notice, the logic of airlines' main safety responsibility is adopted at the regulatory level, which creates a vague space for agent supervision.
2. Multiple training and repeated audit issues
Under the main safety responsibility system, airlines are obliged to train their agents and conduct regular operational safety audits on agents. This is the first 1 vs N; conversely, load balancing agents represent multiple airlines and need to deal with the training and audits conducted by all airlines. This is the second 1 vs N. The two 1 vs N are intertwined, and both airlines and agents are exhausted, the cost is high, and the effect is difficult to estimate.
Especially for airlines that implement the full agency model or have not yet implemented the centralized loading model, they have to rely on the cooperation of load balancing agents at most airports. There is a love-hate relationship between airlines and load balancing agents, which is tangled and tangled.
In 2023, we jointly drafted the "Load Balancing Agent Service Qualification Assessment" group standard with major domestic airlines and airports, aiming to simplify the audit and assessment of agents by airlines by establishing common standards. It has been used by several domestic airlines, but it is still a long way from the original intention of establishing the standard. For details, see: "Load Balancing Agent Service Qualification Assessment" was released and implemented.
3. Inspiration
The new EU regulations will have a three-year transition period and will be implemented in 2028. If the implementation effect is good, it can be used as a reference for the management of load balancing agents in China. On the one hand, by reasonably dividing the rights and responsibilities of operators and agents, the pressure on the main safety responsibilities of airlines can be alleviated, and the reasonable and clear division of rights and responsibilities between agents and airlines can be promoted; on the other hand, through official forces, agent training standards, job qualifications and operational safety audit standardization can be established to completely solve the two-way 1 vs N interweaving situation between airlines and agents.
