Subpart 604 Update: AC 604-004 Issue 03 and the CARs Changes to Track

Issue 03 does far more than tidy up old guidance, and three separate CARs amendments are moving on their own clocks. Here's what changed and what it means for private operators.

Who actually needs a PORD

The new AC separates two questions that used to get blurred together: which aircraft fall under Subpart 604, and which operators actually have to hold a Private Operator Registration Document.

• A PORD is required for private passenger or goods operations using a large aeroplane over 5,700 kg, a turbojet-powered aeroplane, or a turbine-powered pressurized aeroplane certificated for more than six passengers.
• Other aircraft listed under CAR 604.02, including some turbine, pressurized, or multi-engine types, fall within Subpart 604's scope without automatically requiring a PORD. Those operators generally register only if they want a 604 Special Authorization.
• New in Issue 03: reducing an aircraft to six seats by STC does not remove the PORD requirement if the original type certificate covered more than six passenger seats.

Applying for or amending a PORD

The application procedure is considerably clearer now, and amendments are far less painful than operators have assumed.

• New applications use TC Form 26-0821, filed with the regional office responsible for your main base. Email is preferred.
• Amendments use the same form, but you do not complete it again. Provide the legal name and only what's changing, copying your assigned Principal Operations Inspector.

Aircraft registration, and interim or temporary C of Rs

The registration guidance is new, and one part of it is genuinely useful during an acquisition.

• NACIS pulls aircraft data from CCARCS. The registered owner's name must match the PORD applicant's legal name, unless the aircraft is operated under a lease or custody arrangement recognized under CAR 203.03.
• A PORD can be issued against a properly validated Interim Certificate of Registration, and against a Temporary C of R. That removes a chunk of the chicken-and-egg delay mid-acquisition.

Management personnel

Issue 03 adds an entirely new management-personnel discussion. The emphasis is that your Operations Manager, Chief Pilot, and Maintenance Manager must be qualified when appointed and remain qualified afterward.

• CAR 604.141 still gives the Operations Manager two pathways: hold or have held the licence and rating to act as pilot-in-command on an aircraft you operate, or three years of supervisory experience with an operator of comparable size and complexity.
• All three positions must be free of a conviction under Aeronautics Act 7.3, and free of two or more CARs convictions arising from separate incidents.

Training programs finally match how small operations run

This is the area most worth revisiting. CAR 604 does not require every recurrent subject to be taught together in one annual course, and the AC now says so plainly.

• Three structures are expressly recognized: one combined initial and recurrent course, separate initial and recurrent courses, or modular training delivered progressively across the validity period.
• Emergency procedures elements can be spread across the applicable three-year validity period, as long as everything required is completed within it.
• The tradeoff is a tracking system that proves four things: every subject is covered, each is completed in its validity period, nobody is assigned duties requiring training they haven't finished, and competency was established rather than attendance recorded.

Contracted training stays on the books, not the responsibility

A 604 operator may now expressly contract any part of its training program to an outside provider. The responsibility does not travel with it.

• You must ensure the contracted training matches your Operations Manual, that instructors and checkers are qualified, that training is documented as your manual says, and that records stay available to show CARs compliance.
• An Authorized Training Organization's syllabus can now be incorporated into your Operations Manual by reference instead of reproduced in full.
• The old Airline Transport Pilot Licence training section was dropped. Low impact for most operators, since few programs relied on it.

Your Operations Manual isn't "approved," except where it is

Issue 03 is unusually explicit here, and it's worth knowing regardless of how long you've held a PORD.

• You must maintain a current, compliant Operations Manual, but it is not subject to TC approval as a whole document. It must be available to an inspector on request, which is a different thing.
• The exception is material supporting a Special Authorization. Those portions must be submitted so TC can determine whether the SA requirements are met.

Three changes outside the AC, on their own clocks

Three regulatory amendments sit alongside this AC rather than inside it. One is housekeeping, one is already binding on your pilots, and one is coming this November.

• RVSM (February 26, 2025). CAR 604.56 now points to Canadian Standard 624.56 rather than the older FAA and ICAO references. The operational requirement didn't change; the citation did.
• IFR recency (in force June 17, 2026). CAR 401.05 replaced the six-hours-of-instrument-time standard. After the first six months following a qualifying test or check, a pilot exercising IFR privileges needs six instrument approaches in the preceding six months, flown in an aircraft in actual or simulated IMC, as a qualifying instrument flight instructor, in a Level B, C, or D full-flight simulator, or in an appropriate FTD under qualified supervision. A 604 competency check including instrument procedures resets the clock. Keep records three years.
• Aircraft Operating Manual (effective November 19, 2026). SOR/2025-226 amended CAR 604.37(2)(b). Where an AOM is carried instead of the AFM, it must include performance data, limitations, and certificated noise levels from the AFM, clearly identified as AFM requirements. Delayed coming-into-force gives you runway. Use it.