| Instrument | What it is | What it requires | Force |
|---|---|---|---|
| ICAO Annex 11, Chapter 2 §2.28, Appendices 6 & 7 | Global standard | States must adopt fatigue-management regulation: prescriptive scheduling limits, an FRMS, or both. | binding on Contracting States |
| Regulation (EU) 2018/1139, Annex VIII | EU primary law | ATC service provision may not proceed unless fatigue is “managed through a rostering system” addressing duty periods, duty time and rest periods. | directly binding EU law |
| Regulation (EU) 2017/373, Annex IV Part-ATS, ATS.OR.315 & ATS.OR.320 | EU implementing rule | The fatigue policy (315) and the eight-element rostering system (320), the two operative articles. | directly binding EU law |
| AMC1 ATS.OR.315(a), AMC1 ATS.OR.320(a)(6);(7) | Acceptable Means of Compliance | Non-binding ways to demonstrate compliance. Defines night time as 00:00–05:59; supplies almost no other numbers. | non-binding, alternatives allowed |
| Regulation (EU) 2015/340, Annex I Subpart D §§3–4 | EU licensing regulation | Fatigue-prevention training as part of the ATCO's human-factors curriculum, the individual's licence, not the ANSP's rostering system. | directly binding EU law, different subject |
| EUROCONTROL NMD/SAF/2653 & NMD/SAF/2611 | Practitioner guidelines | Practical rostering and fatigue-management guidance. NMD/SAF/2653 sources five case studies and two constraint appendices to SkyRoster. | not law, not AMC |
| UK retained ATM/ANS IR & CAA ORS9 AMC/GM | Post-Brexit national law | The same ATS.OR.320 obligation, retained. The CAA has replaced part of EASA's AMC/GM with SRATCOH-derived values. | binding in the UK only |
Regulation
Seven documents. One binding obligation. A lot of guidance mistaken for law.
A rostering system for European air traffic control sits under one global standard, two EU regulations, their non-binding compliance material, and a set of industry guidelines that carry no legal force at all. Here is exactly where each one sits, and what it actually requires.
The two articles that do the work
Everything above the table exists to produce two paragraphs of EU law
ATS.OR.320, Rostering system(s)
Eight elements the ANSP must specify itself
“Maximum consecutive working days with duty… minimum rest periods… minimum number of rest periods within a roster cycle.” The article names the blanks. It does not fill them in. Full text, EASA's 2023 observed values, and what each element requires of a system.
ATS.OR.315, Fatigue
The policy that gives ATS.OR.320 a named owner
A fatigue management policy, signed by the accountable manager, plus a training programme. Mostly paperwork and process, and this pillar says exactly which parts a rostering system can and cannot touch.
Every page in this pillar
Read the instrument you actually need
Article
ATS.OR.320 in depth
The rostering-system article, quoted in full, element by element.
Article
ATS.OR.315 in depth
The fatigue-policy article, quoted in full, with AMC1's nine policy elements.
Regulation
Regulation (EU) 2017/373, structured
Where Part-ATS sits, how the licensing regulation fits alongside it, and the UK's divergence.
Global
ICAO Doc 9966
The manual behind Annex 11's fatigue standards, prescriptive limits and FRMS, compared.
Comparison
Limits compared
The eight ATS.OR.320 elements against what other States and guidelines actually set.
Article
Consulting controllers
What ATS.OR.320(b) obliges, and what it leaves to the ANSP to decide.
SkyRoster does not certify compliance for you. ATS.OR.320 requires the ANSP to define its own limits and consult its own controllers; no vendor can do either on an ANSP's behalf. What a rostering system contributes is a rule engine that expresses whichever limits are agreed, and a catalogue that documents them, see how at/engine.
Bring us a month that went wrong.
A working session is 45 minutes with your own roster on screen, not a canned demo. Bring a pattern that fought you and we will walk through what the engine would have done with it.