Aircraft leasing comes in three principal forms: dry lease, wet lease, and ACMI. The structure chosen determines not just who pays for fuel or crew, but who holds legal responsibility for your safety. Under a dry lease, the lessee operates the aircraft under its own Air Operator Certificate (AOC) and bears full liability for airworthiness and crew. Under a wet lease or ACMI arrangement, the lessor retains operational control and its AOC governs the flight, meaning the lessor primarily carries legal liability for flight operations and safety. For anyone chartering a private jet or evaluating aviation partnerships, understanding which party holds the AOC on any given flight is the single most important safety question to ask.
TL;DR
- The dry/wet/ACMI distinction is defined by one variable: who provides the crew and holds the operating certificate [flyingfinance.com].
- Under a dry lease, the lessee assumes full operational control and legal liability for safety [nbaa.org].
- Under a wet lease or ACMI, the lessor retains the AOC and primary legal responsibility for flight safety.
- ACMI is a specific wet-lease variant where the lessee covers fuel, ground handling, and trip costs, but not crew or maintenance.
- Dry leases currently account for the vast majority of commercial aircraft arrangements, while the ACMI segment is growing steadily.
About the Author: This article is written by the advisory team at L’VOYAGE, a government-licensed travel agency and private aviation consultancy with over a decade of hands-on experience structuring aircraft arrangements for private clients, corporations, and operators across the APAC region.
What Is a Dry Lease, and Who Is Legally Responsible Under One?
A dry lease is an arrangement in which the lessor provides only the aircraft [nbaa.org]. Nothing else comes with it. No crew, no maintenance program, no insurance coverage. The lessee takes the aircraft and integrates it entirely into its own operation, which means it must hold a valid AOC, hire and certify its own flight crew, manage all airworthiness obligations, and carry appropriate insurance [fliteline.com].
The legal consequence is direct: because the lessee operates under its own AOC, the lessee bears full responsibility for passenger safety and aircraft airworthiness. If something goes wrong operationally, the liability sits with the lessee, not the original aircraft owner.
This structure suits established operators who want access to additional capacity without relinquishing operational control. It is common in commercial aviation: based on 2025 market data, dry leases account for approximately 83.92% of the commercial aircraft leasing market, and the majority of dry lease contracts run five years or longer [commercial.flymarathon.aero].
The analogy that makes the mechanism clear: a dry lease is like renting a car with no driver’s license check from the rental company. You get the vehicle, but you are entirely responsible for driving it legally and safely. The rental company’s name is not on the incident report. Yours is.
What Is a Wet Lease, and How Does Liability Shift?
A wet lease is the structural opposite of a dry lease. Here, the lessor provides not just the aircraft but also the crew, maintenance support, and insurance [aersale.com]. Critically, the aircraft continues to operate under the lessor’s AOC, meaning the lessor retains operational control throughout.
The liability allocation follows the AOC. Because the lessor’s certificate governs the flight, the lessor carries primary legal responsibility for crew performance, airworthiness, and flight operations. The lessee effectively purchases a flying service rather than a bare aircraft [flyingfinance.com].
This is why wet leasing is common in situations where the lessee either lacks an AOC, needs capacity quickly, or operates in a market where obtaining crew certification would be time-prohibitive. Airlines use wet leases during peak seasons or to cover grounded fleets. In private aviation, wet lease structures underpin the majority of on-demand charter arrangements that clients encounter, even if they never see the term on a contract.
What Makes ACMI Different from a Standard Wet Lease?
ACMI stands for Aircraft, Crew, Maintenance, and Insurance. It is a specific category within the wet lease family, and the distinction from a general wet lease is primarily about cost allocation, not legal structure [fliteline.com].
Under ACMI, the lessor covers the four named components. The lessee takes on the remaining operating costs: fuel, ground handling, airport fees, and other trip-specific expenses. The aircraft still operates under the lessor’s AOC, so the liability structure mirrors a standard wet lease.
A practical comparison:
| Feature | Dry Lease | Wet Lease | ACMI |
|---|---|---|---|
| Aircraft provided by lessor | Yes | Yes | Yes |
| Crew provided by lessor | No | Yes | Yes |
| Maintenance by lessor | No | Yes | Yes |
| Insurance by lessor | No | Yes | Yes |
| Operating AOC | Lessee’s | Lessor’s | Lessor’s |
| Fuel and ground handling | Lessee | Lessor | Lessee |
| Primary legal liability | Lessee | Lessor | Lessor |
| Typical contract length | Multi-year [commercial.flymarathon.aero] | Short-term | Per-trip or seasonal |
ACMI arrangements are growing as airlines and operators seek flexible capacity without long-term fleet commitments. The wet lease and ACMI niche is projected to expand at an 8.31% compound annual growth rate going forward.
Why Does This Matter for Private Jet Clients?
Stepping back from the regulatory detail, the practical question for a private charter client is simpler but just as important: on the flight you are about to board, whose AOC is operating it, and has that operator been properly vetted?
Most private jet clients never see the underlying lease structure. They book through a broker, receive a tail number, and board the aircraft. But behind that transaction, the broker should have confirmed which operator’s AOC is active, verified that the operator holds the required insurance, checked the aircraft’s maintenance history, and confirmed compliance with applicable regulations.
This is where broker due diligence becomes a safety function, not just an administrative one. L’VOYAGE maintains a dedicated in-house compliance team that vets every aircraft against proprietary safety standards before it is ever offered to a client. Every flight involves checks on insurance coverage, safety records, legal compliance, and confirmation that the aircraft is legitimately and commercially operated under the correct certificate.
Frequently Asked Questions
What is the simplest way to identify whether a flight is a dry or wet lease?
Check which AOC the aircraft operates under on that flight. If it is the operator providing crew and maintenance, it is a wet lease or ACMI. If the lessee’s own certificate governs operations, it is a dry lease [flyingfinance.com].
Can a private individual be the lessee in a dry lease?
No. A dry lease requires the lessee to hold a valid AOC and the operational infrastructure to support it. Private individuals charter under wet lease or ACMI structures, where the operator’s certificate covers the flight [nbaa.org].
Who pays for fuel under ACMI?
The lessee covers fuel, airport fees, ground handling, and other trip-specific costs. The lessor covers the aircraft, crew, maintenance, and insurance [fliteline.com].
Does the charter price I pay tell me which lease structure is in place?
Not directly. The price reflects the total trip cost to the client, but the underlying operator structure, and therefore the liability allocation, requires the broker to disclose who holds the operating certificate.
Is wet leasing regulated differently by aviation authorities?
Yes. Regulatory treatment varies by jurisdiction, but the FAA and most international authorities treat dry and wet leases as distinct categories with different compliance obligations [nbaa.org].
Why is the ACMI market growing if dry leases dominate overall?
Dry leases dominate by volume because they suit established carriers managing large fleets long-term. ACMI fills a different need: fast, flexible capacity without multi-year commitments, which becomes more valuable as airline schedules grow more volatile.
How does a broker add value if the operator holds all the legal liability?
The broker adds value through vetting. Legal liability resting with the operator does not mean all operators meet the same standard. A broker who checks AOC status, insurance adequacy, maintenance records, and safety ratings before presenting an aircraft is performing a service the client cannot easily replicate alone.
About L’VOYAGE
L’VOYAGE is a government-licensed travel agency and private aviation consultancy founded in 2014 and headquartered in Hong Kong, with offices across Hong Kong, Shenzhen, Kuala Lumpur, and the APAC region. Licensed by the Hong Kong Travel Industry Authority and recognized as the first private jet broker in Asia to hold Wyvern Approved Broker status, L’VOYAGE brings in-house compliance expertise to every charter arrangement. The team, led by CEO Jolie Howard with over 20 years in business aviation, vets every aircraft individually against proprietary safety standards before it reaches a client. For private clients who want to understand not just where they are flying but under whose legal responsibility they are doing so, L’VOYAGE’s consultancy approach answers that question before the flight, not after.
Ready to fly with full clarity on who is responsible for your safety in the air? Reach out to the L’VOYAGE team at lvoyage.aero to discuss your next charter and how L’VOYAGE vets every aircraft before it ever reaches your itinerary.
References
- Wet Lease vs Dry Lease vs ACMI: The Differences Explained (fliteline.com)
- How Does ACMI Leasing Compare to Owning or Dry Leasing Aircraft? | Commercial Aviation (commercial.flymarathon.aero)
- What are the Differences Between Wet Lease, Dry Lease, & Leaseback for Aircraft? (aersale.com)
- Dry Lease vs. Wet Lease Aircraft: The Complete 2026 Guide (flyingfinance.com)
- Aircraft Leasing | NBAA – National Business Aviation Association (nbaa.org)