FAQ n.136915

Is it allowed for a Russian citizen to fly an unmanned aircraft system (UAS) for an operator registered in the European Union? Does it matter whether they are resident in a Member State or Russia?

Answer

Russian citizens, as employees (or similar), are permitted to fly a UAS for the benefit of operators that are not subject to the sanctions. It does not matter whether those Russian citizens have a residence in the European Union or not.

However, Russian citizens are not allowed to fly Russian-registered UAS or non-Russian registered UAS that are owned or chartered(2) or otherwise controlled(2) by a Russian natural or legal person, entity or body. This means, for example, that Russian citizens cannot fly their own UAS in the European Union or use a UAS operated by an EU company or a company from a third country which is controlled by a Russian natural or legal person.

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

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