China: CAAC Consults on Aviation Collaborative Operations Rules

On August 31, 2026, the Civil Aviation Administration of China (CAAC) opened public consultation on the draft Provisions on Civil Aviation Collaborative Operational Management (《民用航空协同运行管理规定》), a departmental-rule-grade instrument that would replace the 2024 collaborative-operations measures (民航规〔2024〕32号) and, for the first time, attach enforceable liability to failures of airline, airport and air traffic management coordination. The CAAC Operations Monitoring Centre (运行监控中心) issued the notice under the Comprehensive Deepening Civil Aviation Reform Action Plan and the 14th Five-Year legislative plan; comments are due by October 8, 2026, sent to [email protected].

The draft moves collaborative operations from a normative-document 办法 to a binding 规定 and adds a dedicated legal-liability chapter (法律责任). Listed failures expose airlines, airport operators and air traffic management units to a warning and fines of up to RMB 30,000, plus regulatory interviews (约谈) and linkage to the flight-normality assessment. For practitioners, the shift is from "should coordinate" to "must coordinate, on defined technical standards, or be sanctioned".

Who must build A-CDM, and to what standard?

Large airports handling 10 million or more passengers annually must stand up an airport collaborative decision-making (A-CDM) mechanism and build the A-CDM system to the CAAC industry standard MH/T 6125. Airport clusters, the multi-airport systems around Beijing, Shanghai and Guangzhou, must additionally establish a regional CDM mechanism that coordinates throughput across the cluster rather than airport by airport. The draft thus hardens what was guidance into a build obligation with a named technical reference and a sanction behind it.

What operational data must airlines, airports and ATM share?

The Provisions require airlines, airport operators and air traffic management to share defined operational data across the CDM mechanism, including target off-block times (TOBT) and the ground-air collaborative release sequence that drives departure predictability. The obligation is reciprocal: each actor must furnish its data inputs so the mechanism can deconflict capacity and reduce large-scale flight delay. The draft frames data sharing as the operational core of the regime, not an ancillary best practice, and ties non-compliance directly to the liability chapter.

What penalties apply, and who is exposed?

The new legal-liability chapter is the substantive change. Where the 2024 measures set expectations, the draft 规定 makes listed failures sanctionable: a warning and a fine of up to RMB 30,000, with regulatory interviews and flight-normality assessment consequences for recurrence. The exposed operators are the Chinese network carriers, Air China, China Eastern, China Southern and Hainan, the Capital, Shanghai and Guangdong airport groups, the Air Traffic Management Bureau, and foreign carriers operating into China, who must now comment on the text and prepare for a legally enforceable CDM build.

Continuous, per-jurisdiction monitoring surfaces this kind of change the moment it publishes.

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File comments on the draft by the October 8, 2026 deadline using the CAAC feedback form, focusing on the A-CDM build threshold, the MH/T 6125 conformity scope and the liability triggers. Audit whether each hub your airline or group operates crosses the 10 million passenger threshold, and whether your cluster falls under the regional CDM duty. Brief flight operations, airport coordination and ATM liaison teams on the data-sharing inputs the mechanism will require, target off-block times included, and map the gap between current practice and the sanction-backed standard. The full draft text and the consultation notice are published on the CAAC opinion-solicitation page, with the draft Provisions (征求意见稿) attached. Obsidian tracks this consultation through to adoption so a compliance team can act on the binding text, not just the draft.