Trust · Safety · Compliance
Click and Flyward introduces pilots to aircraft owners and handles the paperwork around a hire. It does not operate flights. That single fact is what keeps the model on the right side of UK aviation law, and keeps responsibility with the people who can actually carry it.
“Click and Flyward is a neutral introduction platform. It is not an aircraft operator, air carrier or insurer, holds no Air Operator Certificate, and is not a party to the rental agreement between owner and hirer. The decision to release an aircraft rests solely with the owner; the decision to accept and fly it, and responsibility as operator and pilot-in-command, rests solely with the hirer.”
FL050 · The legal model
Renting an aircraft to a pilot who flies it themselves is a private operation, even though money changes hands. It clears every test that would otherwise make it commercial. This is how UK flying clubs have run self-fly hire for decades.
Test 1 · Who is the operator
On a dry hire the pilot takes continual effective disposal of the aircraft, so the pilot becomes the operator and pilot-in-command. The registered owner is only presumed to be the operator until a hire agreement shows otherwise. Rebutting that presumption is the heart of the model.
ANO 2016, Article 4 · Regulation (EC) 785/2004, Article 3(c)
Test 2 · Not commercial air transport
No fare-paying passengers are carried. The pilot flies for their own purposes, so there is no carriage for reward. No Air Operator Certificate and no operating licence are required.
UK Regulation (EU) 965/2012 · ANO 2016, Articles 103 and 105
Test 3 · Not public transport
The money is paid to hire the aircraft as a chattel, not as consideration for carriage on a particular flight. That is the precise line the law draws, and self-fly hire sits on the private side of it.
ANO 2016, Article 6 · Schedule 1 (valuable consideration)
Test 4 · Not a commercial operation
The pilot is the operator and has full control of the aircraft. There is no operator providing a service to a customer, so the commercial-operation rules do not bite.
ANO 2016, Article 7
Cost-sharing platforms let a pilot take passengers who contribute to the direct costs of that flight, capped and with no profit. Click and Flyward is different: a pilot hires an aircraft and flies it themselves. We say so plainly in our terms so the model is never read through the cost-sharing rules. UK Regulation (EU) 965/2012, Article 6(4a)
Scope: the marketplace is limited to UK-registered, standard Certificate of Airworthiness aircraft flown within the UK. Permit-to-fly types (homebuilts, microlights) carry separate hire restrictions and are out of scope for this proof of concept.
FL080 · Responsibility
The most important question for any hire is who ensures the pilot is fit to fly that particular aircraft. The answer is the owner, supported by evidence we collect. Here is the full split.
| Obligation | Responsible | Basis in law |
|---|---|---|
| Hold a valid licence (PPL, LAPL or CPL) | PILOT | Reg (EU) 1178/2011, Part-FCL |
| Hold a valid medical | PILOT | Reg (EU) 1178/2011, Part-MED |
| Hold the correct class or type rating for the aircraft | PILOT | Reg (EU) 1178/2011 |
| Meet recency and currency requirements | PILOT | 1178/2011 · Part-NCO · owner terms |
| Act as operator and pilot-in-command, plan and fly the flight safely | PILOT | ANO 2016, Articles 4, 68, 69 |
| Keep the aircraft airworthy: Certificate of Airworthiness, ARC, maintenance | OWNER | ANO 2016, Art 33 · Reg 1321/2014 |
| Keep the aircraft registered | OWNER | ANO 2016, Articles 24 and 25 |
| Hold insurance that permits rental and covers the hirer | OWNER + pilot meets open-pilot terms | Reg (EC) 785/2004, Articles 4, 6, 7 |
| Satisfy themselves the hirer is competent on that aircraft, and release it | OWNER | Common law (bailment) · insurer open-pilot warranty |
| Keep the flight private rather than commercial | PILOT OWNER | ANO 2016, Articles 6 and 7 |
| Protect the personal data pilots submit | FLYWARD | UK GDPR · Data Protection Act 2018 |
| Run the marketplace lawfully | FLYWARD | Consumer, e-commerce and payments law |
The platform never appears in the rows that carry aviation-safety duties. That is by design.
What the platform does
What the platform never does
FL095 · Insurance
An owner must hold a policy that permits self-fly hire to third parties and covers the hiring pilot, by name or under an open-pilot warranty with minimum hours and ratings. A pilot who falls below those minima voids the cover, which is exactly why owners run a checkout.
We surface the excess on every listing and hold a refundable deposit against it. We do not underwrite anything ourselves. Hull cover is the owner's commercial choice; third-party liability cover is a legal minimum.
Minimum third-party liability
Per Regulation (EC) 785/2004, by maximum take-off mass. SDR is the IMF Special Drawing Right.
Data protection
A pilot's medical is health data, the most sensitive category under UK GDPR. We record only a declared type and expiry date rather than storing the certificate itself, to keep special-category data to a minimum. Documents are encrypted, retained only as long as needed, and shared with an owner only when a pilot asks to hire their aircraft. UK GDPR · Data Protection Act 2018
FL110 · Before launch
This proof of concept reflects our own research into UK aviation and marketplace law. It is not legal advice. Before going live, a qualified UK aviation solicitor would confirm the points below, which is where the real risk for the platform owner is managed.
Being open about this is deliberate. A platform that visibly designs around the hard parts is more credible than one that pretends they do not exist.
References
Air Navigation Order 2016 (SI 2016/765) - operator, public transport, commercial operation, airworthiness, registration.
UK Regulation (EU) 965/2012 - air operations, the CAT definition and cost-sharing.
UK Regulation (EU) 1178/2011 - flight crew licensing, ratings and medical.
UK Regulation (EC) 785/2004 - insurance requirements and minima.