Airline bans rarely happen overnight. They are the end point of a regulatory chain: an international audit or sustained evidence of poor oversight, followed by targeted assessments from regional safety authorities, and finally administrative decisions that restrict or bar operations. For Air Tanzania, rapid fleet expansion and ambitions for longer haul services increase exposure to those exact checks.
Start with the audit framework. ICAO’s Universal Safety Oversight Audit Programme, now conducted under the Continuous Monitoring Approach, measures a State’s effective implementation of eight critical elements of safety oversight. The audit produces a percentage Effective Implementation score and a set of protocol-question findings that are specific and technical. A failed or poorly performing USOAP-CMA assessment does not itself ban operators. What it does is identify systemic oversight gaps that make other authorities reluctant to rely on that State’s certificates.
How does a weak ICAO audit translate into operational restrictions for an airline? Two mechanisms matter most. First, regional regulators and safety agencies use ICAO findings as inputs to separate gatekeeping tools, most notably the European TCO authorisation process. EASA will only issue a Third Country Operator authorisation when it is satisfied that an applicant complies with minimum ICAO standards and other EU requirements. If the State oversight recorded in USOAP-CMA is judged inadequate, EASA can withhold or delay TCO approval and may carry out on-site verifications before granting access. Second, governments and blocs maintain safety lists and operating restrictions that target either specific carriers or all carriers from a State when oversight is demonstrably poor. Both measures effectively prevent commercial access to the affected airspace until corrective actions are proven.
What kinds of ICAO findings are most likely to trigger denial of access? In practice, the critical triggers are those that show the regulator cannot reliably monitor or enforce airworthiness and operations. Examples include an inspectorate with insufficient qualified staff, lack of functioning procedures for continuing airworthiness and major maintenance monitoring, gaps in personnel licensing or training oversight, an ineffective State Safety Program or Safety Management System oversight, and shortfalls in accident investigation independence or capability. These map directly to the USOAP-CMA critical elements and are exactly the items other authorities look for when assessing whether to accept certificates issued by the State.
From an operator and national-law perspective the legal pathway is straightforward but onerous. The State regulator must produce a corrective action plan that addresses the root causes identified by ICAO, demonstrate timely and documented implementation, and allow international assessors to verify fixes. Airlines must then show that their own Safety Management System, manuals, maintenance programmes, training records, and quality assurance data are fully aligned with both ICAO SARPs and the expectations of destination regulators. For Air Tanzania, that means parallel work at the company and state level; fixing airline practice without demonstrable improvement in state oversight will not remove external restrictions.
Operational workarounds are limited and tightly controlled. EASA’s TCO framework provides some narrow pathways, such as one-off notifications for urgent public-interest missions and detailed technical specifications for any authorisation that is granted. Leasing or wet-lease arrangements from carriers that already hold approved authorisations are an option to continue commercial links, but they do not substitute for a national remediation programme and do not address reputational or insurance impacts.
What should Air Tanzania and the Tanzania Civil Aviation Authority prioritise to avoid a ban or to reverse restrictions quickly if they appear? Practical, verifiable, and timebound corrective steps include: (1) publish and resource a clear corrective action plan tied to specific USOAP findings; (2) shore up the inspectorate through targeted recruitment, competency-based training, and documented inspector oversight; (3) tighten continuing airworthiness controls including traceability of maintenance records, timely compliance with airworthiness directives, and robust contract oversight of third-party MRO providers; (4) accelerate airline-level SMS implementation, recurrent training, and quality assurance audits with transparent results; and (5) invite early cooperative assessments from ICAO and, where appropriate, EASA or other regional partners so that third-party verifications can restore confidence. These are not cosmetic fixes. They require investment, governance changes, and a willingness to submit to external verification.
A final legal note: transparency matters more than ever. When regulatory authorities provide clear, evidence-based updates about progress against audit findings, international counterparts have the information they need to make risk-based decisions. That reduces the likelihood of blunt instruments like broad operating bans and instead encourages calibrated, time-limited measures tied to demonstrable corrective action. For an airline seeking overseas growth, that kind of disciplined governance is not optional. It is the legal and regulatory foundation on which international access is built.