Ground Handling Contracts and Liability in Türkiye

Ground handling covers a range of services supporting an aircraft, its passengers and cargo on the ground. It is not a single undifferentiated activity. In Türkiye, the Airport Ground Handling Regulation (SHY-22) connects the relevant services to authorisation and contractual requirements. An agreement alone does not authorise an unlicensed service.

This guide examines the regulation originally published on 23 August 2016, together with the amendments of 9 December 2025 and 5 May 2026. It addresses licence groups, agreements, responsibility, cargo operations, staff and sanctions. The detailed service descriptions are supplemented by SHGM’s SHT-YHT instruction.

1. Legal framework and service types

SHY-22 regulates authorisation, oversight, standards and fees for ground services. Airport operators, handling organisations and air carriers each have regulatory responsibilities under Article 6. The framework derives from Turkish Civil Aviation Law No. 2920 and the relevant presidential-decree provisions.

Article 5 lists representation; passenger services; load control and communications; ramp services; cargo and mail; aircraft line maintenance; flight operations; transport; catering; supervision and administration; and aircraft special-security services and inspection. The exact scope of a service is determined by the applicable instruction and authorisation, rather than a broad commercial description.

2. Licence groups and conditions

Article 13 generally requires a separate operating licence for each airport and each service type. Representation licences have a special rule permitting coverage of airports open to civil traffic. The licence must correspond to the actual operation, and statutory exceptions require their own legal basis.

• Group A: Covers the full range or, at minimum, passenger services, load control and communications, ramp, and cargo and mail. A first-time applicant must organise at least those services at three airports open to international traffic. Minimum paid-up capital is the Turkish-lira equivalent of USD 3 million, with the prescribed USD 1 million definitive, indefinite bank guarantee to the airport operator.
• Group B: Allows air carriers to provide permitted services for their own operations, excluding transport services and subject to the applicable domestic/foreign-carrier rules. The prescribed bank guarantee is USD 100,000.
• Group C: Covers specified services such as representation, supervision and administration, catering, flight operations, aircraft special security, and cargo and mail. Minimum paid-up capital is the Turkish-lira equivalent of USD 200,000 without cargo/mail, or USD 500,000 with cargo/mail. Cargo/mail operations require the prescribed USD 250,000 guarantee.
• Group D: Concerns eligible entities operating special-purpose Group C airport terminals under SHY-33B, rather than the airport operator itself. Minimum paid-up capital is the Turkish-lira equivalent of USD 500,000 and the prescribed guarantee is USD 250,000.

The regulation contains additional corporate, shareholding, management and voting requirements. For relevant Group A/C/D applications, registered-share and Turkish management/voting conditions must be checked against Article 7; transfers and capital changes may require prior SHGM permission. Financial amounts alone are not a complete eligibility test.

The process involves preliminary permission and an operating licence, with responsibilities allocated between SHGM and the airport operator under the current rules. For the build-operate-transfer airports identified in Article 6(4), the 2026 amendment specifically assigns the relevant preliminary-permission, licence and agreement procedures to DHMİ. Do not assume every airport follows an identical administrative route.

Licences are generally valid for two years, cannot be transferred and are renewed subject to continuing compliance and the required renewal procedure. Responsible management, Form 4 approvals, equipment, personnel, quality systems and, where applicable, ISAGO requirements also matter.

3. The contractual chain

Air carrier–handler: Article 17 requires a standard ground handling agreement for regular commercial passenger and cargo operations. More than four planned flights over two consecutive months count as regular operations for this purpose. Agreements are to conform to the IATA standard agreement and are submitted to the airport operator where approval is required. Terminated agreements must be notified, and the current list of approved agreements is published by the operator.

The SGHA edition, main agreement and annexes actually incorporated must be obtained and reviewed. Referring to “SGHA” is not a substitute for reading the service scope, liability terms, claims provisions and negotiated amendments. This article does not reproduce IATA’s contractual text.

Handler–airport operator: The licensed organisation must also enter into the standard airport service contract. This is a separate two-year contractual layer governing obligations to the operator and monetary consequences of breaches. Its terms cannot override the regulation.

Permitted subcontracting: Certain labour-intensive services, including relevant loading/unloading, cabin cleaning, cargo/mail and movement-area driving or equipment-operation tasks, may be entrusted to eligible Group A/C organisations with prior permission and an agreement under Article 11. The subcontractor’s responsibilities do not extinguish those of the commissioning licence holder.

Article 18 generally prevents a carrier from contracting with multiple handlers for the same service type at the same airport. The May 2026 amendment introduces a specific exception for domestic carriers’ aircraft special-security service and inspection. The exception should not be extended to all services.

Service prices are agreed between the provider and recipient within the regulatory framework; below-cost pricing is prohibited. The regulation distinguishes passenger-aircraft seating capacity and cargo-aircraft maximum take-off weight in the relevant fee provisions. The operator’s right-to-provide-service fee is distinct from the handler’s commercial service price.

4. Liability and insurance

Regulatory responsibility: Airlines, airport operators and handlers remain responsible for their respective statutory duties. An allocation of loss in a commercial agreement does not remove those public-law obligations.

Contractual and civil liability: The SGHA, airport service contract and subcontract determine many issues concerning damage, delay, indemnities and recourse. However, mandatory law and the applicable carriage or tort rules also matter. Liability is not determined by contractual wording alone, and a limitation clause is not automatically valid for every type of conduct or claimant.

Insurance: Article 19 requires the relevant organisations, including subcontractors, to maintain liability cover for damage associated with their services to airport facilities, aircraft, service equipment and third parties. The airport operator determines and periodically reviews the required per-accident minimum. Policy limits, exclusions and the contractual allocation of risk should be compared.

Passengers and shippers: The carrier is generally the contractual counterparty under the carriage agreement. That does not automatically exclude a possible claim against another responsible person under the applicable rules. Any recourse between carrier and handler requires its own assessment.

Operational evidence: Weight-and-balance calculations for each flight, signatures of trained staff and the required retention of flight records are important evidence. Article 19 requires the relevant weight-and-balance records to be kept in the flight file for at least three months. Representation and supervision providers also bear duties concerning regulatory compliance and the accuracy of supplied information.

The carrier must arrange the necessary passenger care for relevant delays under the applicable rules. At the cargo/ramp/aircraft interface, Article 18 places responsibility on the relevant carrier for the proper performance of the specified transfer, loading and unloading operations. Clear handover records and contractual recourse terms reduce evidential disputes.

5. Cargo and mail

The regulation distinguishes cargo from baggage, mail and specified aircraft-related supplies. Carriers may not accept cargo from an agency lacking the required SHGM authorisation. Ground-handling and cargo-agency authorisations should be verified separately.

For Group C cargo/mail activities, the prescribed SHY-33B bonded temporary-storage or warehouse authorisation and the required airside/landside boundary location with direct airside access must be checked. Possessing only a storage or warehouse authorisation is not equivalent to being authorised for every stage of handling.

Relevant organisations must employ appropriately trained dangerous-goods personnel and comply with the applicable competency-based training requirements. Cargo-aircraft fees, custody handovers, incident reporting and insurance should be addressed in the operating documents. Carrier liability for cargo loss or damage is examined separately in part six of this series.

6. Ground staff and employment law

Ground-service employees generally fall within the Labour Act, unlike the excluded aircrew discussed in earlier articles. Their actual duties and employment arrangements must nevertheless be examined. SHT-FTL flight/cabin-crew limits should not simply be substituted for the ground worker’s working-time rules.

Airside driving requires the relevant training and permits, including special equipment qualifications where applicable. Access-card withdrawal or loss of a driving permit can prevent an employee from performing a task. That does not automatically establish a lawful dismissal: suitable alternative duties, the duration and cause of the restriction, contractual terms and employment protections must be assessed.

Management staff require the relevant Form 4 approvals. Outsourcing may give rise to principal-employer/subcontractor rules and joint liability under Labour Act Article 2 where the legal conditions are met; a commercial subcontract does not establish or eliminate those conditions by itself. Shift work, night work, overtime and balancing arrangements require their own compliance review in a round-the-clock operation.

7. Supervision and sanctions

Article 22 provides differentiated responses to failures in licence conditions, safety risks, service disruption, personnel/equipment breaches and incorrect information. Some situations involve notice and an opportunity to remedy, while an immediate operational safety risk may require work to stop. Suspension, cancellation and administrative fines have different conditions.

The provision includes, for specified breaches, 30-day corrective periods and staged suspension/cancellation, while repeated provision of incorrect information can lead to a 90-day suspension and further consequences. These are not interchangeable deadlines applying to every infringement. Certain licence cancellations also trigger a two-year restriction on re-licensing and consequences for the relevant owners, partners or authorised managers, subject to the exact statutory ground.

The actual administrative decision, service contract and current regulation must be read together. Record the date of notification and identify the appropriate review route promptly. Paying a contractual penalty does not necessarily resolve regulatory or third-party liability.

8. Sources

• SHY-22 Airport Ground Handling Regulation, originally published 23 August 2016, Official Gazette No. 29810.
• Amending regulation of 5 May 2026, Official Gazette No. 33244; particularly Articles 6(4), 7/A and the special-security exception.
• SHGM’s December 2025 consolidated text, to be read with later amendments.
• SHGM instructions: SHT-YHT and the relevant dangerous-goods training instruction.
• Turkish Civil Aviation Law No. 2920; SHY-33B; Labour Act No. 4857, particularly Article 2 and working-time provisions; the applicable IATA SGHA and negotiated annexes.