FAQ n.136912

Is it allowed for Russian citizens to fly, either as pilot-in-command or co-pilot, a non-Russian-registered aircraft that performs flights under a non-Russian air operator certificate (AOC), or an aircraft whose owner is not Russian?


Yes, such flights are allowed provided that:

  1. the pilot is an employee (or similar) of an air carrier or aircraft operator; and
  2. the aircraft is not operated by a Russian air carrier, not registered in Russia, and not owned or chartered(2) or otherwise controlled(1) by any Russian natural or legal person, entity or body.

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.

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