According to the Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Annex III Organisation requirements for air operations [Part-ORO] of Commission Regulation (EU) 965/2012 on air operations, Subpart GEN – General Requirements, Section 2 Management, “AMC1 ORO.GEN.200(b)- Management system” for “SIZE, NATURE AND COMPLEXITY OF THE ACTIVITY”, is prescribed that:

(a) An operator should be considered as complex when it has a workforce of more than 20 full time equivalents (FTEs) involved in the activity subject to Regulation (EC) No 216/20085 and its Implementing Rules.

(b) Operators with up to 20 FTEs involved in the activity subject to Regulation (EC) No 216/20086 and its Implementing Rules may also be considered complex based on an assessment of the following factors:

(1) in terms of complexity, the extent and scope of contracted activities subject to the approval;

(2) in terms of risk criteria, the extent of the following:

(i) operations requiring a specific approval;

(ii) high-risk commercial specialised operations;

(iii) operations with different types of aircraft used; and

(iv) operations in challenging environment (offshore, mountainous area, etc.).

Therefore, is considered as “Complex”