Brazil’s ANAC Proposes Voluntary Pilot Safety Reporting Programme: How PROAS Would Work

Brazil’s National Civil Aviation Agency (ANAC) has opened a public consultation on a proposed voluntary safety reporting programme for airline pilots. Known as PROAS, the initiative would initially cover pilots working for operators certified under RBAC 121, with the aim of encouraging safety reporting through a collaborative, non-punitive framework subject to specific conditions.

Brazil Opens Consultation on a New Voluntary Safety Reporting Framework

Launched on November 9, 2026, the public consultation invites industry stakeholders to comment on the proposed Programa de Ação em Segurança Operacional (PROAS). Led by ANAC’s Operational Safety Advisory Office (ASSOP), the consultation remains open until December 16, 2026. The programme has not yet been formally established.

The proposal seeks to address a limitation of existing aviation safety reporting systems: operational errors, deviations and potentially hazardous situations may not always be reported through established channels. By encouraging voluntary disclosures, ANAC aims to obtain additional information about the circumstances and contributing factors behind safety events, supporting earlier identification of operational risks.

PROAS draws on the Aviation Safety Action Program (ASAP) developed by the US Federal Aviation Administration (FAA). The American model promotes voluntary reporting through collaborative arrangements between regulators, aviation organizations and participating employees. ANAC is considering a Brazilian framework based on similar principles, adapted to its own regulatory environment.

The consultation follows preparatory regulatory analysis conducted earlier in 2026. At this stage, ANAC is seeking feedback on the proposed framework rather than implementing a new reporting obligation. Any operational rollout would depend on subsequent regulatory decisions and participation arrangements.

Why PROAS Would Initially Apply to RBAC 121 Airline Pilots

ANAC’s proposal would initially limit PROAS to pilots employed by airlines certified under Brazil’s RBAC 121 regulations, which govern specified public air transport operations. Participation would be voluntary for operators, and pilots would not automatically be covered simply because their airline holds an RBAC 121 certificate. The framework could eventually extend to other professional groups or aviation segments, depending on the development and evaluation of the initial programmes.

Under the proposed structure, an ANAC resolution would establish the general principles, while operator-specific instruments, including a Portaria and a Termo de Adesão (Adherence Agreement), would define how each participating airline applies the programme. These arrangements would address reporting procedures, responsibilities, eligible events and monitoring requirements, allowing implementation to reflect individual operational circumstances.

PROAS would complement, rather than replace, existing safety reporting obligations. Brazil already operates a mandatory occurrence reporting framework under ANAC Resolution No. 714/2023. The proposed programme would provide an additional channel for identifying hazards and examining contributing factors through voluntary disclosures, alongside the reporting and risk management processes already established within airlines’ Safety Management Systems (SMS).

How Event Review Committees Would Handle Safety Reports

A central feature of the proposed PROAS framework is the creation of Event Review Committees, known in Portuguese as Comitês de Revisão de Eventos (CRE). These committees would bring together representatives of ANAC, participating airlines and the professional groups covered by the programme. Their role would be to review eligible reports collaboratively, identify operational hazards and recommend measures to prevent similar events.

Rather than treating every reported deviation primarily as an enforcement matter, the proposed process would examine the circumstances surrounding an event. Committee members would consider contributing factors and determine appropriate safety actions. The emphasis would be on understanding operational risks and supporting corrective measures, subject to the programme’s eligibility criteria and exclusions.

Responsibilities would be shared among the participating parties. Airlines would be expected to provide reporting channels, operational support and resources for the review process, while ANAC would contribute regulatory oversight and participate in the programme’s governance. Representatives of the professionals concerned would also have a role in encouraging participation and reviewing eligible events.

The framework also envisages monitoring the programme through indicators such as the number of reports received, their acceptance rates, identified hazards and the implementation of recommended safety actions. The precise reporting arrangements would depend on the regulatory instruments and participation agreements ultimately adopted.

This collaborative approach resembles the FAA’s Aviation Safety Action Program (ASAP), which uses agreements between aviation organizations, the regulator and, where applicable, employee representatives. However, ANAC’s proposed Brazilian procedures would be governed by their own regulatory framework rather than automatically adopting the American programme’s provisions.

Confidentiality, Reporting Safeguards and the Next Regulatory Steps

Confidentiality and conditional non-punitive treatment are among the principal safeguards under consideration. According to ANAC’s technical proposal, individual safety reports would be retained within participating operators’ internal systems, while information shared with the authority would generally be consolidated and de-identified. These arrangements are intended to encourage reporting while protecting sensitive information.

The proposed protections would not amount to unrestricted immunity from disciplinary or regulatory consequences. The technical documentation identifies exclusions involving intentional safety violations, criminal conduct, inappropriate use of alcohol or psychoactive substances, deliberate falsification and certain repeated behaviours. Eligibility for non-punitive treatment would therefore depend on the nature of the event and compliance with the programme’s conditions.

Participating airlines would also be subject to programme oversight. The proposed framework contemplates suspension or termination of participation in circumstances such as repeated non-compliance, serious confidentiality breaches or failures to address identified deficiencies. The detailed conditions would need to be confirmed in the final regulatory instruments.

For airlines, implementing PROAS would consequently involve more than introducing an additional reporting channel. Participation would require clearly defined responsibilities, appropriate governance arrangements and procedures for reviewing reports and monitoring safety actions. These requirements remain proposals rather than obligations already imposed under an operational PROAS framework.

ANAC is accepting contributions through Brasil Participativo until December 16, 2026. The consultation covers the programme’s governance, reporting safeguards, eligibility criteria and implementation procedures. No definitive entry-into-force date has been announced, and any rollout would depend on subsequent regulatory decisions and participation arrangements.

Sources : ANAC / Brasil Participativo — Tomada de Subsídios nº 01/ASSOP/2026: Proposed PROAS Framework

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