FAQ n.136911

As a Russian citizen, am I allowed to fly an aircraft for private purposes in the airspace of the European Union (e.g. exercise the privileges of my PPL, SPL, BPL or national pilot license issued to fly Annex I aircraft, such as microlights, etc.)? Can I rent, borrow for free, or use an aircraft of a flying club to exercise my private pilot privileges?

Answer

Russian citizens, regardless of them holding another citizenship, can exercise private pilot privileges to land in, take off from or overfly the territory of the European Union in a non-Russian-registered aircraft which is NOT owned or chartered(2) or otherwise controlled(1) by any Russian natural or legal person, entity or body.

This means that Russian citizens are not prevented from renting, borrowing for free, or otherwise using aircraft of a flying club to exercise their private pilot privileges.

However, Russian citizens are prohibited to exercise private pilot privileges to pilot a Russian-registered aircraft, or a non-Russian-registered aircraft that is owned or chartered or otherwise controlled by a Russian natural or legal person, entity or body (cf. Article 3d of Regulation (EU) No 833/2014). This means, for example, that Russian citizens cannot fly their own aircraft in the EU airspace or use an aircraft of an EU company or of a third-country company that is controlled by a Russian natural or legal person.  

Competent authorities will monitor such private flight activities to ensure that they are not performed in a way to circumvent the sanctions outlined in Article 3d of Regulation (EU) No 833/2014.

Note 1: The concept of ‘control’ is understood in the ‘economic’ or ‘financial’ sense and not in the ‘technical’ or ‘operational’ sense (cf. para 48 of Judgement of the General Court Case T-233/22).

Note 2: The EU aviation law does not define ‘aircraft charter’. Member States authorities should apply the definition of ‘charter’ in accordance with their national legislation and relevant international agreements.

Last updated
08/03/2024

Was this helpful?