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Regulation · Part-ATS

ATS.OR.320, the article that specifies what a rostering system must control

This is the one article in EU law that describes a rostering system rather than a policy. It does not hand you the numbers. It hands you eight blanks and tells you, and your controllers, to fill them in together.

The instrument

Regulation
(EU) 2017/373
Annex
IV, Part-ATS
Subpart
A, Section 3
Article
ATS.OR.320
Title
Air traffic controllers' rostering system(s)
In force
Applied from January 2020

The article, verbatim

(a) An air traffic control service provider shall develop, implement and monitor a rostering system in order to manage the risks of occupational fatigue of air traffic controllers through a safe alternation of duty and rest periods. Within the rostering system, the air traffic control service provider shall specify the following elements:

  1. maximum consecutive working days with duty;
  2. maximum hours per duty period;
  3. maximum time providing air traffic control service without breaks;
  4. the ratio of duty periods to breaks when providing air traffic control service;
  5. minimum rest periods;
  6. maximum consecutive duty periods encroaching the night time, if applicable, depending upon the operating hours of the air traffic control unit concerned;
  7. minimum rest period after a duty period encroaching the night time;
  8. minimum number of rest periods within a roster cycle.

(b) An air traffic control services provider shall consult those air traffic controllers who will be subject to the rostering system, or, as applicable, their representatives, during its development and its application, to identify and mitigate risks concerning fatigue which could be due to the rostering system itself.

ATS.OR.320, Regulation (EU) 2017/373, Annex IV (Part-ATS)

Consultation under (b) is not a side note. Read the full requirement, what it does and does not oblige, atconsulting controllers on a rostering system →

Observed practice, not the rule

What 36 ATSPs actually specified, in 2023

ATS.OR.320 sets no numbers, so EASA measured what ANSPs set for themselves. This table is not a target and not a benchmark, it is what a representative sample of the regulation's own addressees chose, for the same eight elements, split by the two kinds of unit the study distinguished.

ElementACC averageACC std. dev.Aerodrome (TWR) averageTWR std. dev.
(1) Max. consecutive working days (days)5.91.45.81.7
(2) Max. hours per duty period (hours)9.23.010.52.7
(3) Max. time on ATC service without breaks (minutes)903815489
(4) Ratio of duty periods to breaks0.690.100.720.10
(5) Min. duration of rest periods (hours)11.65.312.05.1
(6) Max. consecutive duty periods encroaching night (days)2.31.02.91.2
(7) Min. rest after a duty period encroaching night (hours)22.519.517.815.5
(8) Min. number of rest periods within a roster cycle3.72.03.74.5

EASA, Study on the Analysis, Prevention and Management of Air Traffic Controller Fatigue, Table 2-1, p.25, final report, May 2024, 36 of 46 EASA-Member-State ATSPs surveyed

The standard deviations are the honest part of this table. A 19.5-hour standard deviation on element 7 for ACCs means the eight-element structure is common across Europe; the actual values under it are not. Two ANSPs can both be fully compliant with ATS.OR.320 and run rosters that would fail each other's rules.

How this shows up in a rostering system

Where each element becomes a rule, not a number

This is the product half of the page, kept separate from the article above on purpose: everything in this section is about SkyRoster, and everything above it stands on its own without SkyRoster in it.

verifiedRule names below compiled from the product source on 12 September 2026, see the full catalogue at/engine/rules.

FAQ

Questions this article actually answers

Does ATS.OR.320 set the actual numeric limits, such as maximum hours per duty?

No. The article requires the ANSP to specify its own values for the eight elements. EASA's Acceptable Means of Compliance provide guidance on only one of them (AMC1 ATS.OR.320(a)(6);(7), which defines night time). The ANSP sets the numbers, not the regulator.

Is consulting controllers a formality, or a hard requirement?

It is a condition of the article, not a courtesy. ATS.OR.320(b) states the ANSP “shall consult those air traffic controllers who will be subject to the rostering system, or, as applicable, their representatives, during its development and its application.”

What counts as night time under ATS.OR.320?

AMC1 ATS.OR.320(a)(6);(7) states: “Night time should be considered as the time between midnight and 05.59.”

Does ATS.OR.320 apply only to area control centres, or also to towers?

The article sits under ATS.OR.300 (Scope), which applies to the air traffic control service provider generally, with no carve-out for aerodrome towers. EASA's 2024 fatigue study reports separate observed values for Area Control Centres and Aerodromes, confirming both are in scope.

Do EUROCONTROL's rostering guidelines carry the same legal force as ATS.OR.320?

No. NMD/SAF/2653 and NMD/SAF/2611 are EUROCONTROL guidance documents, not EU law. ATS.OR.320 is a binding requirement under Regulation (EU) 2017/373; the guidelines are practical material an ANSP can draw on when deciding how to meet it.

Bring your own eight numbers.

If you already have values for the eight elements, we will show you exactly how each one becomes a rule the engine enforces, hard or soft, at whichever layer the roster can actually break it.