CAD     – List of Changes in the Register of RAs/RACSFs as from 14 Apr 2021
民航處   – RAs/RACSFs登記冊變更名單

Register of RAs  on 14 Apr 2026

Register of RACSFs  on 31 Mar 2026 

CAD Notice to RAs
民航處致管制代理人通告 

CAD Notice to RACSFs 
民航處致管制空運貨物安檢設施通告

Please click here for more information about ICAO 2021 Policy Direction

RA Inspections Findings by the CAD for Year 2025

民航處於2025年巡查管制代理人所得的結果

To enhance the security awareness of RAs, the most common deficiencies for year 2025 are shared by CAD. Members (who are RAs) please take note of the following areas and avoid such deficiencies accordingly. 

1. Did not conduct internal security awareness training for own staff and/or contractor staff in accordance with the intended frequency specified in the Regulated Agent Security Programme (RASP) and properly maintain the records.

2. Did not properly maintain warehouse and/or transportation contractor declarations.

3. Did not maintain the job application form and/or job interview record templates in accordance with RAR requirements.

4. Did not conduct regular self-assessment at least once every two years and maintain the records for three years.

5. Did not conduct recurrent background check or properly maintain such records to every staff with access to consignment designated as air cargo and/or its related shipping documents who have been under employment for two years or above.

Besides, RAs were observed to have committed major deficiency. They were found to have committed either of the following:-

(i) Not having qualified persons to take up the position of Nominated Persons, or

(ii) Tendered unknown cargo as known cargo.

These cases were handled in accordance with the mechanism for handling deficiencies promulgated in Notice to RAs 6/2021.  The RAs were required to submit a corrective action plan and propose effective corrective measures to the satisfaction of CAD, and ensure their continual compliance with the RAR requirements. Follow-up inspections were being conducted to verify the conformance. On a separate note, Notice to RAs 6/2025, which introduced the revised mechanism for handling deficiencies, had superseded Notice to RAs 6/2021 and came into effect since 1 January 2026.

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

A new Notice to RAs is being prepared to draw the attention of RAs on the common issues observed and the corresponding recommendations / best practices.

RACSF Inspection Findings by the CAD for Year 2025

民航處於2025年巡查管制空運貨物安檢設施所得的結果

To enhance the security awareness of RACSFs, the most common deficiencies for year 2025 are shared by CAD. Members (who are RACSFs) please take note of the following areas and avoid such deficiencies accordingly. 

1. Did not conduct internal security awareness training for internal and contractor staff in accordance with the intended frequency specified in RACSF Security Programme and properly maintain the records.

2. Did not properly maintain maintenance and calibration records of screening equipment of the past two years.

3. Did not maintain X-ray images and hand search photos of all consignments screened in the previous 31 days.

4. Did not ensure the availability of records of all CCTV cameras for the previous 31 days.

5. Did not maintain complete screening records (i.e. screening log and screening receipt) of the past three months.

Besides, RACSFs were observed to have committed major deficiency. They were found to have committed either of the following:-

(i) Tendered unscreened cargo as screened cargo, 

(ii) Failed to implement effective security measures to prevent unlawful interference or ensure tamper-evident of screened cargo, or 

(iii) Using unqualified screening equipment for screening.

These 12 cases were handled in accordance with the mechanism for handling deficiencies promulgated in Notice to RACSFs 4/2021. The RACSFs were required to submit a corrective action plan and propose effective corrective measures to the satisfaction of CAD, and ensure their continual compliance with the RACSF requirements. Follow-up inspections were being conducted to verify the conformance. Effective from 1 January 2026, non-compliance with RACSF requirements will be handled in accordance with the revised mechanism for handling deficiencies stipulated in Notice to RACSFs 3/2025 promulgated on 31 December 2025.

To ensure the continual compliance with the RACSF requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RA Inspections Findings by the CAD for Year 2024

民航處於2024年巡查管制代理人所得的結果

To enhance the security awareness of RAs, the most common deficiencies for year 2024 are shared by CAD. Members (who are RAs) please take note of the following areas and avoid such deficiencies accordingly. 

1. Fail to maintain proper self-assessment records or accurately reflect in them the status of operations for quality control purpose.  

2. Fail to properly maintain consignment documents or ensure the data on the documents were accurate or duly completed.  

3. Fail to include all requirements specified in the Regulated Agent Security Programme (RASP) Part II Section 11 in job application form or job interview record. 

4. Fail to properly maintain internal security awareness training records of contractor staff. 

5. Fail to properly maintain documents involved in inter-RA handling (e.g. Form of Undertaking for Inter-RA AWB Handling, and Regulated Agent Aviation Security Declaration. 

Besides, 10 RAs were observed to have committed major deficiency.  All were found to have no qualified persons to take up the position of Nominated Persons.  These cases were handled in accordance with the mechanism for handling deficiencies promulgated in Notice to RAs 6/2021.  The RAs were required to submit a corrective action plan and propose effective corrective measures to the satisfaction of CAD, and ensure their continual compliance with the RAR requirements. Follow-up inspections were being conducted to verify the conformance. 

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RACSF Inspection Findings by the CAD for Year 2024

民航處於2024年巡查管制空運貨物安檢設施所得的結果

To enhance the security awareness of RACSFs, the most common deficiencies for year 2024 are shared by CAD. Members (who are RACSFs) please take note of the following areas and avoid such deficiencies accordingly. 

1. Fail to properly maintain register of security seals used for tendering known cargo.

2. Fail to include all information as required in the Regulated Air Cargo Screening Facility Security Programme (RACSF SP) in the security screening receipt and security screening log. 

3. Fail to observe all requirements on internal security awareness training for internal and contractor staff and maintain records properly . 

4. Fail to maintain an up-to-date RACSF SP to reflect the latest particulars and operation of RACSF. 

5. Fail to include all information as required in the Handling Procedures for RACSFs in the pre-declaration for tendering known cargo to other RA/RACSF.

Besides, 12 RACSFs were observed to have committed major deficiency. They were found to have committed either of the following:-

(i) Tendered unscreened cargo as screened cargo, 

(ii) Failed to implement effective security measures to prevent unlawful interference or ensure            tamper-evident of screened cargo, 

(iii) Not having any qualified person to take up the position of Nominated Person, 

(iv) Conducted screening operation for air cargo at the new warehouse before acceptance of                such warehouse by this Department, or 

(v) Failed to implement previous CAP. 

These 12 cases were handled in accordance with the mechanism for handling deficiencies promulgated in Notice to RACSFs 4/2021. The RACSFs were required to submit a corrective action plan and propose effective corrective measures to the satisfaction of CAD, and ensure their continual compliance with the RACSF requirements. Follow-up inspections were being conducted to verify the conformance. 

To ensure the continual compliance with the RACSF requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RA Inspections Findings by the CAD for Year 2023

民航處於2023年巡查管制代理人所得的結果

To enhance the security awareness of RAs, the most common deficiencies for year 2023 are shared by CAD. Members (who are RA) please take note of the following areas and avoid such deficiencies accordingly. 

1. Fail to include all requirements specified in the Regulated Agent Security Programme (RASP) Part II Section 11 in job application form or job interview record.  

2. Fail to correctly annotate the security status (i.e. “SPX”) on inter-RA co-loading documents.  

3. Fail to maintain Shipper’s Letter of Instruction (SLI) or to ensure the data (such as quantity and weight) appeared on the SLI were accurate or duly completed. 

4. Fail to maintain proper self-assessment records or accurately reflect in them the status of operations for quality control purpose. 

5. Fail to maintain internal security awareness training records of internal and contractor staff. 

Besides, 2 RAs were observed to have committed major deficiency. Both were found to have tendered unknown cargo as known cargo as they failed to ensure that the warehouse processing screened cargo under their custody was under continuous CCTV surveillance. These two cases were handled in accordance with the mechanism for handling deficiencies promulgated in Notice to RAs 6/2021. The RAs were required to submit a corrective action plan and propose effective corrective measures to the satisfaction of CAD, and ensure their continual compliance with the RAR requirements.  CAD had conducted follow-up inspections verifying the conformance.  

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RACSF Inspection Findings by the CAD for Year 2023

民航處於2023年巡查管制空運貨物安檢設施所得的結果

To enhance the security awareness of RACSFs, the most common deficiencies for year 2023 are shared by CAD. Members (who are RACSF) please take note of the following areas and avoid such deficiencies accordingly. 

1. Fail to include all requirements specified in the Regulated Air Cargo Screening Facility Security Programme (RACSF SP) Part II Section 6 in job application form or job interview record.  

2. Fail to include all information as required in the RACSF SP in the security screening receipt and security screening log. 

3. Fail to properly maintain register of security seals used for tendering known cargo. 

4. Fail to maintain proper self-assessment records or accurately reflect in them the status of operations for quality control purpose. 

5. Fail to maintain internal security awareness training records of internal and contractor staff.

Besides, 5 RACSFs were observed to have committed major deficiency. They were found to have either tendered unscreened cargo as screened cargo, or failed to implement effective security measures to prevent unlawful interference or ensure tamper-evident of screened cargo, or using unqualified screening equipment for screening. These 5 cases were handled in accordance with the mechanism for handling deficiencies promulgated in Notice to RACSFs 4/2021. The RACSFs were required to submit a corrective action plan and propose effective corrective measures to the satisfaction of CAD, and ensure their continual compliance with the RACSF requirements.  CAD had conducted follow-up inspections verifying the conformance. 

To ensure the continual compliance with the RACSF requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RA Inspections Findings by the CAD for Year 2022

民航處於2022年巡查管制代理人所得的結果

To enhance the security awareness of RAs, the most common deficiencies for year 2022 are shared by CAD. During the regular inspections conducted by CAD, deficiencies were mostly found in the following areas (in order), and Members (who are RA) please take note and avoid such deficiencies accordingly. 

1. Fail to maintain documentation of inter-RA activities, such as Form of Undertaking for Inter-RA AWB Handling (FoU) and Regulated Agent Aviation Security Declaration (RAASD), with proper format in accordance with the Regulated Agent Security Programme (RASP) and Handling Procedures for RAR. 

2. Fail to correctly annotate the security status (i.e. “SPX”) on inter-RA co-loading documents, such as mistakenly annotated "SPX" when tendering unknown cargo to other RAs. 

3. Fail to include the requirements specified in RASP in job application form or job interview record. 

4. Fail to maintain self-assessment records or accurately reflect in them the status of operations for quality control purpose. 

5. Fail to maintain internal security awareness training records (including internal staff and contractor staff). 

Besides, 6 RAs were observed to have committed major deficiency. They were found to have either failed to implement a previous corrective action plan (CAP) or without any qualified persons to take up the position of Nominated Persons for Cargo Security due to expiry of training qualifications or change in personnel. They were required to submit a corrective action plan to the satisfaction of CAD to ensure their continual compliance with the RAR requirements, and CAD would conduct follow-up inspections to verify the conformance. 

As mentioned in Special Circular dated 25 July 2022, Members may be aware that the Reminders of RASP Requirements and Common Issues Observed after Full Implementation of ICAO’s Policy Direction has already been promulgated in Notice to RAs No. 1/2022 on CAD's website. 

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RACSF Inspection Findings by the CAD for Year 2022

民航處於2022年巡查管制空運貨物安檢設施所得的結果

To enhance the security awareness of RACSFs, the most common deficiencies for year 2022 are shared by CAD as set out below. During the regular inspections conducted by CAD, deficiencies were mostly found in the following areas (in order), and Members (who are RACSF) please take note and avoid such deficiencies accordingly. 

1. Fail to include the requirements specified in RACSF Security Programme (RACSF SP) in job application form or job interview record. 

2. Fail to maintain internal security awareness training records (including internal staff and contractor staff). 

3. Fail to renew the Contractor declarations every two years using the latest version available on CAD website. 

4. Fail to conduct regular self-assessment at least once every two years and/or maintain the record for two years. 

5. Fail to conduct recurrent background checks at least once every two years for existing staff members with access to consignment designated as air cargo and /or related documents. 

6. Fail to maintain register of security seals used for tendering known cargo.

Besides, 5 RACSFs were observed to have committed major deficiency. They were found to have either tendered unscreened cargo as screened cargo, or failed to implement effective security measures to prevent unlawful interference or ensure tamper-evident of screened cargo. They were required to submit a corrective action plan to the satisfaction of CAD to ensure their continual compliance with the RACSF requirements, and CAD would conduct follow-up inspections to verify the conformance. 

As mentioned in Special Circular dated 25 July 2022, Members may be aware that the Reminders of RACSF SP Requirements and Common Issues Observed after Full Implementation of ICAO’s Policy Direction has already been promulgated in Notice to RACSFs No. 1/2022 on CAD's website. 

To ensure the continual compliance with the RACSF requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RA Inspections Findings by the CAD for 2021

To enhance the security awareness of RAs, the most common deficiencies for the period mentioned, especially after the phasing out of account/known consignors recognized by RAs and implementation of 100% security screening, are shared by CAD (Civil Aviation Department). During the regular inspections conducted by CAD for the year 2021, deficiencies were mostly found in the following areas (in order) and Members (who are RA) please take note and avoid such deficiencies accordingly.

1.  Fail to maintain proper self-assessment records or accurately reflect in them the status of operations for quality control purpose. 

2.  Fail to correctly annotate the security status (i.e. “SPX”) on inter-RA co-loading documents, such as mistakenly annotated "SPX" when tendering unknown cargo to other RAs. 

3.  Fail to include the requirements specified in Regulated Agent Security Programme (RASP) in job application form or job interview record. 

4.  Fail to maintain the internal security awareness training record of warehouse or transportation contractors. 

5.  Fail to correctly select the declared status of cargo consignment being tendered to a cargo terminal operator (CTO) when completing the Form of Undertaking for Inter-RA AWB Handling (FoU), such as mistakenly selected “Known Cargo” (i.e. “SPX”) on the FoU when unknown cargo was tendered to CTO for security screening. 

Besides, 7 RAs were observed to have committed major deficiency. They were found to have either tendered unknown cargo as known cargo, failed to implement a previous corrective action plan (CAP) or without any qualified persons to take up the position of Nominated Persons for Cargo Security due to expiry of training qualifications or change in personnel. They were required to submit a corrective action plan to the satisfaction of CAD to ensure their continual compliance with the RAR requirements, and CAD would conduct follow-up inspections to verify the conformance. 

As mentioned in Special Circular dated 23 June 2021, Members may be aware that the revised mechanism for handling deficiencies committed by RAs has already been promulgated in Notice to RAs No. 6/2021 on CAD's website.  

In addition, per News 68 dated 04 February 2022, Members may wish to note that a new requirement was disseminated to RAs in late January 2022 on recurrent background check to be conducted at least once every two years for existing staff members with access to consignment designated as air cargo and/or related documents. A Sample Recurrent Background Check Record template and new updates to other RAR documents (e.g. RASP, Handling Procedures for RAR, Warehouse / Transportation Contractor Declarations) were uploaded on CAD's website concurrently. 

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RA Inspections Findings by CAD for Year 2020

To enhance the security awareness of RAs, the Civil Aviation Department (CAD) shared an update regarding the RA inspection findings for 2020.  During the regular inspections conducted by CAD for the year 2020, deficiencies were similar to those identified last year and mostly found in the following areas:- 

1. Fail to maintain a proper register of KC or information as shown in the KCDoC is incomplete*

2. Fail to maintain full-set of shipping documents or the format of the shipping documents (e.g. annotations of RA code, SPX/SCO*) are not in accordance to RASP/Handling Procedures for RAR

3. Fail to maintain proper records for inter-Regulated Agent handling (e.g. Regulated Agent Aviation Security Declaration and Form of Undertaking for Inter-RA AWB handling)

4. Fail to maintain a recruitment record systematically or requirements specified in Regulated Agent Security Programme (RASP) are not included in the job application form or job interview form 

5. Fail to maintain the proper random X-ray screening records and self-assessment records for quality control purpose

* From 1 March 2021, all existing account/known consignors recognised by RAs will phase out and the security status “SCO” will no longer exist. 

Besides, 21 RAs were observed to have tendered unknown cargo as known cargo. They were required to submit a corrective action plan to the satisfaction of CAD to ensure their continual compliance with the RAR requirements, and CAD would conduct follow-up inspections to verify the conformance.

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

Major Deficiencies Observed by CAD in Recent Inspections on RAs

民航處於近期巡查管制代理人時所發現的嚴重缺失  on 29 Dec 2020 

CAD Notice to RAs

民航處致管制代理人通告

RA Inspections Findings by CAD for Year 2019

To enhance the security awareness of RAs, the Civil Aviation Department (CAD) shared an update regarding the RA inspection findings for 2019. During the regular inspections conducted by CAD for the year 2019, deficiencies were similar to those identified last year and mostly found in the following areas:-

1. Fail to maintain a proper register of KC/AC (KC/AC master list) or information as shown in the KCDoC/ACDoC is incomplete

2. Fail to maintain full-set of shipping documents or the format of the shipping documents (e.g. annotations of RA code, SPX/SCO) are not in accordance to RASP/Handling Procedures for RAR

3. Fail to maintain internal security awareness training or subsequent record, e.g. training was not provided for the warehouse and transportation contractors

4. Fail to maintain a recruitment record systematically or requirements specified in RASP are not included in the job application form or job interview form

5. Fail to maintain the proper random X-ray screening records and self-assessment records for quality control purpose

Besides, some RAs were observed to have tendered unknown cargo as known cargo. They were required to submit a corrective action plan to the satisfaction of CAD to ensure their continual compliance with the RAR requirements, and CAD would conduct follow-up inspections to verify the conformance. One of them was de-registered for failing to submit the corrective action plan.

Furthermore, some RAs failed to comply with the training requirements. Three of them were de-registered for failing to provide the valid RAR certificates of their Nominated Person for Cargo Security and Second Trained Person within the given time frame after the inspection.

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

RA Inspections Findings by CAD for January - November 2018

During the regular inspections conducted by CAD in January - November 2018, deficiencies were mostly found in the following areas:-

1. Fail to maintain a proper register of KC/AC (KC/AC master list) or information as shown in the KCDoC/ACDoC is incomplete

2. Fail to maintain full-set of shipping documents or the format of the shipping documents (e.g. annotations of RA code, SPX/SCO) are not in accordance to RASP/Handling Procedures for RAR

3. Fail to maintain internal security awareness training or subsequent record, e.g. training was not provided for the warehouse and transportation contractors

4. Fail to maintain recruitment record systematically or requirements specified in RASP are not included in the job application form or job interview form

Besides, some RAs were observed having tendered unknown cargo as known cargo.  The RAs concerned were required to submit a corrective action plan to the satisfaction of CAD to ensure their continual compliance with the RAR requirements, and CAD would conduct follow-up inspections to verify the conformance.  One RA was de-registered for failing to submit a corrective action plan, and another RA was de-registered for failing to implement the submitted corrective action plan.  For any future cases with similar deficiencies identified, immediate suspension of the RA concerned would be imposed, until a corrective action plan to the satisfaction of CAD is received.

To ensure the continual compliance with the RAR requirements, CAD may conduct announced or unannounced inspections in addition to the regular inspection scheduled.

Deficiency Statistics of RA Inspections 2014

In response to HAFFA’s request, CAD provided the summary of RA inspection findings [download here] with the statistics on the deficiencies found by the CAD inspectors during audit check conducted from 01 January to 31 December 2014. Please note the following deficiencies as listed on the table:

1. Fail to maintain record of KC/AC declaration systematically or information as shown on the KC/AC declaration is incomplete (74.3%) -- Highest percentage!

2. Fail to maintain full-set of shipping documents in accordance to RASP/RA Handling Procedures or the format of the shipping documents (annotations of RA code, SPX/SCO) not in accordance to RASP/RA handling Procedures (50.9%)

3. Lack of physical security to protect cargo against unlawful interference or record of Warehouse Contractor Declaration/Transportation Contractor Declaration do not properly maintain (13.1%)

4. Fail to verity the status of RA (i.e. Inter-RA procedures) or record of RA declaration do not maintain systematically (i.e. Inter-RA form (RAASD) keeping) (10.1%)

5. Fail to maintain recruitment record systematically or requirements specified in RASP not included in recruitment form (9.3%)

6. Fail to maintain record of QCP (random screening) (9.1%)

7. Fail to maintain training record including initial RA training records and subsequent in-house training (6.3%)

8. Major Deficiency – Tendering unknown cargo as known cargo (no record of security control and KC declaration signed) (4.2%)

The above deficiencies might be due to RA’s inadequate quality assurance and they could be rectified if RAs improve their internal quality control procedures and/or by staff training.