Transport Canada CARs 703/704 FRMS: Prescriptive Rules vs. Alternate Plan

Transport Canada amended the flight and duty time regulations for CARs 703 (air taxi) and 704 (commuter) operators, effective December 2022. The new rules introduced updated prescriptive limits and the option to submit an alternate Fatigue Risk Management System (FRMS) plan.

The changes align with ICAO fatigue management standards and give operators two compliance paths: follow the new prescriptive rules exactly, or develop and submit an FRMS alternate plan for Transport Canada approval.

The prescriptive path requires compliance with the updated duty period limits, rest requirements, and cumulative hour restrictions. For many operators, this is the simpler path — no additional plan submission required.

However, the new prescriptive limits are more restrictive in some areas. Operators whose schedules relied on the flexibility of previous rules may find the prescriptive path operationally constraining.

The FRMS alternate plan allows operators to deviate from prescriptive limits if they can demonstrate equivalent or better fatigue management through a formal FRMS. This requires a detailed plan submission including hazard identification, risk assessment, mitigation strategies, and monitoring procedures.

The FRMS plan must be approved by Transport Canada before implementation. Approval timelines have been variable — some operators report months of back-and-forth with their POI. Plan early.

Start by assessing whether your current scheduling practices comply with the new prescriptive limits. If they do, the prescriptive path is lower effort. If they do not, you need either schedule restructuring or an FRMS alternate plan.

If pursuing FRMS, build on your existing safety data. Use duty time records, fatigue reports, and operational data to support your risk assessments. The stronger your data foundation, the faster the approval process.

Track CARs 703/704 compliance alongside your other regulatory requirements in Navlyt Compliance — particularly if you operate under both Canadian and U.S. regulatory frameworks.