EU restrictive measures against Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

For more information, please see 'Restrictive measures – Russia's military attack on Ukraine'.

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

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Common Issues - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

What is the legal basis for the EU restrictive measures against Russia?

What does “technical assistance” mean?

Do the Sanction Regulations restrict a Russian citizen holding a personnel licence issued in accordance with Regulation (EU) 2018/1139 to exercise the privileges of the licence inside the EU (e.g. flying an aircraft for private purposes or for an EU airline, conducting maintenance for an EU aircraft, working in an EU Part 145 organisation, working as cabin crew in EU airlines)?

Who must comply with the provisions of the Regulation? What about holders of dual EU-Russia citizenship?

Is it allowed to execute contracts that have been concluded before the adoption of the sanctions (e.g. deliveries with EASA Form 1, Form 52)?

We understand that following evaluation of the terms „technical assistance” and “other services” as mentioned in the Sanctions Regulations, EASA has suspended certificates issued to organisations in Russia. Is this interpretation also applicable to approvals and certificates issued by EU Member States in the same way?

As the holder of an organisation approval (DOA, POA, MOA, CAMO, etc) granted under Regulations (EU) 748/2012 or 1321/2014, can I use my privileges for products, parts or appliances to be used by any natural or legal person, entity or body in Russia or for use in Russia?

Design certificates and design organisation approvals - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

What actions has EASA taken concerning design certificates and design organisation approvals?

Do the Sanctions Regulations supersede the continued airworthiness obligations of the EU type certificate holders (TCHs) stemming from Regulation (EU) No 748/2012, hence the continued airworthiness (CAW) support to Russian operators and owners should be stopped?

Does the definition of “technical assistance” cover the provision of safety-related information?

Am I allowed to send any type of technical information, including safety information related to the design, to my customer in Russia, or maintain my Russian customer’s access to my dedicated IT system for such information (e.g. service bulletins, manuals)?

Are EU organisations permitted to answer questions received from FATA about on-going validation of modifications?

Will EASA issue flight condition to Russian products issued with an EASA type certificate?

Can a holder of a design organisation approval (DOA) apply to EASA for a supplemental type certificate (STC) or other design approval (e.g. minor change) for a product, part or non-installed equipment, that is to be installed on an aircraft operated by a Russian operator?

Can a holder of a design organisation approval (DOA) issue design approvals under its privileges, that is to be used on an aircraft operated by a Russian operator?

EASA suspended aircraft type certificates issued to organisations in Russia. Can the individual aircraft of these types registered in EU Member States continue to be operated by EU operators?

Will EASA continue to monitor, and eventually adopt FATA Airworthiness Directives for Russian types whose type certificate was suspended by EASA?

Will ADs issued by EASA to Russian types that were recently suspended remain valid?

My organisation is holder of a type certificate issued by EASA and a Russian operator of my product reported an occurrence to us. Are we allowed to have an exchange with the Russian operator to investigate the reported occurrence?

Production organisations - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

As the holder of a Production Organisation Approval (POA) granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I release engines, propellers, parts or appliances with an EASA Form 1 to a customer in Russia, or for use in Russia?

As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I have approved or unapproved location(s) in Russia from where I exercise my privileges granted under 21.A.163?

As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I issue the EASA Form 52 (Aircraft Statement of Conformity) or the EASA Form 53 (Certificate of Release to Service) for an aircraft registered in Russia, owned by a Russian entity, or to be operated in Russia?

As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I issue a Permit to Fly for an aircraft registered in Russia, owned by a Russian entity, or to be operated in Russia?

Aircraft maintenance and continuing airworthiness - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

What actions has EASA taken in the domain of aircraft maintenance?

As an organisation approved in accordance with Regulation (EU) 1321/2014, am I allowed to provide maintenance services to Russian operated*, registered, or owned aircraft which is for use in Russia, including engines, components and parts thereof?

Is it allowed for a maintenance organisation to provide maintenance services to Russian aircraft subject to the sanctions, including engines, components and parts thereof, to facilitate their storage while they are banned from operating in the EU airspace, e.g. to park aircraft for short term storage, engine preservation etc.?

Is it allowed for an EU maintenance organisation to perform maintenance in Russia in accordance with Regulation (EU) 1321/2014 on EU registered aircraft in order for them to meet the airworthiness requirements necessary for the return flight or in order to meet their leasing return conditions?

Is it allowed for a maintenance organisation approved by EASA under Part-145 to perform maintenance on components and provide such components to a non-EU, non-Russian operator, if this operator operates the aircraft to Russia?

Can maintenance services be provided to aircraft operated by an EU operator which is owned by a Russian citizen/entity?

EASA suspended certain type certificates (TCs) issued to holders in Russia in accordance with the Sanctions Regulations. A maintenance organisation has one of those TC on its approval. As the competent authority for such maintenance organisation, do we have to limit or suspend partially the approval of the organisations with respect to the suspended TC?

Training and licensing of maintenance personnel - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

What actions has EASA taken concerning training of maintenance personnel?

I am an EU national and holder of a Part-66 licence. Am I allowed to work, either within or outside the EU, on Russian owned or operated aircraft?

The Sukhoi Superjet type certificate is suspended by EASA. In the Member States there are Part-66 licences containing this type rating. Does the competent authority need to suspend this rating in those maintenance licences?

As an organisation approved by a Member State in accordance with Annex IV (Part-147) of Regulation (EU) 1321/2014 and my principal place of business is within the territory of the EU, am I allowed to provide training to Russian citizens?

As competent authority of an EU Member State, am I allowed to issue Part-66 licence to a Russian national?

Aircrew training and licensing - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

What actions has EASA taken in the domain of pilot licensing?

I am an EU national and holder of a pilot licence issued in accordance with Annex I (Part-FCL) to Regulation (EU) No 1178/2011. Am I allowed to fly, either within or outside the EU, a Russian owned, registered or operated aircraft?

If a training organisation subject to Regulation (EU) No 1178/2011 operates a simulator manufactured by a Russian manufacturer and simulating Russian aircraft, is it affected by the sanctions?

If Ukrainian pilot wants to validate his/her licence, but getting a verification from Ukrainian CAA is limited or even impossible, what are the options for such pilot to get a Part-FCL license?

Do the same principles apply to balloon and sailplane pilot training, testing and checking (e.g. Russian citizens, training sites, etc.) in accordance with Regulations (EU) 2018/395 and (EU) 2018/1976 as to training, testing and checking in accordance with Regulation (EU) No 1178/2011?

Are EU sanctions also applicable to pilot training, testing and checking for aircraft listed in Annex I to Regulation (EU) 2018/1139 (‘EASA Basic Regulation’), such as microlights?

As an ATO/organisation operating FSTDs subject to Regulation (EU) No 1178/2011 and having principal place of business outside the EU territory, am I allowed to provide either theoretical or practical training, in an FSTD or in an aircraft, to Russian citizens?

Aircraft operations - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

Are aircraft registered in Russia or operated by Russian operators allowed to fly into the EU?

Regulation (EU) 833/2014 prohibits any non-Russian-registered aircraft which is owned or chartered, or otherwise controlled by any Russian natural to land in, take off from or overfly the territory of the Union, except in case of an emergency landing or emergency overflight. Does this prohibition coverall also natural persons with a dual nationality?

What happens to the dry and wet leasing arrangements and code-sharing agreements between the EU AOC holders and Russian aircraft operators?

My organisation is a navigational database provider established in the EU. Am I allowed to provide updates of my product to my Russian customer?

Is it allowed to register, and then fly an aircraft in an EU Member State when the aircraft is owned by a company incorporated in the EU, but the owner of that company is a Russian natural person?

Why do the restrictive measures not include a general ban on an air carrier established in the EU (an AOC) from operating aircraft that would fall within the scope of article 3d(1) of Regulation (EU) No 833/2014 for flights outside the EU?

EASA TCO authorisations - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

Are Third Country Operator authorisations issued by EASA to airlines from Russia still valid?

Is a TCO one off-notification under TCO.305 of Regulation (EU) No 452/2014 needed from a Russian operator for flight(s) performed under an exemption granted by a Member State in accordance with Article 3d (3) of Regulation (EU) No 833/2014?

Operation of unmanned aircraft - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

Are Russian unmanned aircraft operators registered in the EU Member State allowed to operate unmanned aircraft within the EU?

How to conduct in a case, where a drone operator from Russia wants to conduct a drone show in MS. The application is issued by MS applicant, but every document they have provided us (including operations manual and risk assessment), indicates clearly that the actual operator is indeed Russian operator.

ATM/ANS - Restrictive measures Russia

Disclaimer:
The information included in the frequently asked questions (FAQs) has been coordinated with relevant services of the EU Commission and intends to help and give guidance to national authorities, EU operators and citizens for the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014. The FAQs do not have binding effect. Under the EU Treaties, Member States are responsible for implementing EU law in their national legal system. In case of individual matters, please contact your competent authority.

 

Are Aeronautical Database Suppliers (DAT) located in the EU permitted to continue to supply aeronautical information to customers in Russia?

Are Aeronautical Database Providers (DAT Providers) located in the EU permitted to continue to receive aeronautical information from Russian authoritative sources (e.g. Russian AIP), necessary to build their products?

With regards to technical assistance, in particular the dissemination of aeronautical information, can this be provided to Russian operators when they are operating over the Atlantic Ocean?