Aircrew training and licensing - Restrictive measures Russia

EASA has suspended all flight simulation training device (FSTD) qualification certificates issued by EASA to organisations in Russia.

No. The personal scope of Regulation (EU) No 833/2014 covers any person inside or outside the territory of the Union who is a national of a Member State.

In principle, it is prohibited to provide technical assistance, brokering services or other services related to the aviation goods and technology and to the provision, manufacture, maintenance and use of those goods and technology, directly or indirectly to any natural or legal person, entity or body in Russia or for use in Russia.

The definition of “technical assistance” is set in Article 1(c) of Regulation (EU) No 833/2014, as amended by Regulation (EU) 2022/328, and it means any technical support related to repairs, development, manufacture, assembly, testing, maintenance, or any other technical service, and may take forms such as instruction, advice, training, transmission of working knowledge or skills or consulting services, including verbal forms of assistance.

Training could be allowed if done for the purpose of later operating a non-Russian aircraft, i.e. if the student or candidate is e.g. destined to fly as an employee on an EU airline. If the intention is to fly in Russia or Russian controlled/registered aircraft, then such training would be support to the use of banned aircraft or operators and hence prohibited. For private pilots (who presumably would be flying themselves and are Russian citizens) such training is not allowed. Furthermore, the training cannot take place in Russia.

Training, testing and checking could be allowed if done for the purpose of later operating a non-Russian aircraft i.e. if the student or candidate is e.g. destined to fly as an employee on an EU airline. If the intention is to fly in Russia or Russian registered aircraft, then such tests would be support to the use of banned aircraft or operators and hence prohibited. For private pilots (who presumably would be flying themselves and are Russian citizens) such examinations or checks are not allowed. Furthermore, the skill tests, proficiency checks or assessments of competence cannot take place in Russia.

Training, testing and checking could be allowed if done for the purpose of later operating a non-Russian aircraft i.e. if the student or candidate is e.g. destined to fly as an employee on an EU airline. If the intention is to fly in Russia or Russian registered aircraft, then such examinations would be support to the use of banned aircraft or operators and hence prohibited. For private pilots (who presumably would be flying themselves and are Russian citizens) such examinations are not allowed. Furthermore, the examination cannot take place in Russia.

Such licence issue would necessitate some training, testing and checking, including contacts with the Russian licensing authorities, which is currently not possible.

The same restrictions as for other training, testing and checking activities should apply here. If the person would fly as an employee of a non-sanctioned (EU) operator, then this is permitted.

The sanctions covered by Regulation 833/2014 do not limit import of goods from Russia, nor the support given by the Russian manufacturer to their use in the EU. If the training is provided to persons that are not subject to the sanctions (i.e. not Russian persons or intending to operate aircraft subject to the sanctions) it may continue also, provided that the FSTD operator is able to continue to maintain its qualification certificate.

However, this answer is without prejudice to the possibility that these companies are owned or otherwise controlled by a person or entities subject to an asset freeze. If that were the case, it would limit possibility to trade with these companies.

Ukrainian citizens are not subject to sanctions, so normal rules (i.e. Regulation (EU) 2020/723) apply. Under the current circumstances, it is understandable that the Ukrainian CAA may not be able to provide normal service for verifications. Therefore, Member States might consider for example using the flexibility provided by EASA Basic Regulation Article 71 to facilitate such conversions, taking also account of the possibility to mitigate any safety risks e.g. by the use of more comprehensive skill tests and interviews.

Yes, provided that the purpose of the license is to operate a non-Russian aircraft, i.e. if the person is e.g. destined to fly as an employee on an EU airline. If the intention is to fly in Russia or Russian registered aircraft, then handing over the licence would be support to the use of banned aircraft or operators and hence prohibited. For private pilots (who presumably would be flying themselves and are Russian citizens) the license should not be handed over.

Yes, provided that the purpose of the medical certificate is to operate a non-Russian aircraft, i.e. if the person is e.g. destined to fly as an employee on an EU airline. If the intention is to fly in Russia or Russian registered aircraft, then the person cannot be issued with an EU medical certificate as that would be support to the use of banned aircraft or operators and hence prohibited. For private pilots (who presumably would be flying themselves and are Russian citizens) no EU medical certificate should be issued.

Yes. Regulation (EU) 833/2014 does not differentiate between the different types of aircraft. Therefore, balloon and sailplane pilot licensing should be treated in the same manner as pilot licensing for any other aircraft.

Yes. Since the scope of the Sanctions regulations is much broader than that of the EASA Basic Regulation, the Sanctions regulations apply to pilot training, testing and checking for all types of aircraft, even if they do not fall under the scope of the common EU aviation safety legislation.

Approved training organisations and organisations operating FSTDs which have their principal place of business (PPoB) outside the EU are reminded that the privileges of their ATO approval or FSTD qualification certificate is to provide training, or to use the device for the purpose of obtaining a pilot licence, rating, or certificate in accordance with Regulations (EU) No 1178/2011. When receiving requests from Russian citizens, these organisations should first verify whether it would be possible for a Member State to issue licences to these applicants, after completion of the training, testing or checking. EU Member States have certain restrictions in terms of issuing licenses to Russian citizens.

Furthermore, these organisations are also reminded that their training sites or FSTDs located within the territory of the EU are fully subject to the restrictions of the Sanctions Regulations, hence they should apply the same principles as the organisations having their PPoB in the Member States. Therefore, please also consult the FAQs relevant to EU organisations.

Finally, as regards practical training, organisations should keep in mind that the Sanctions Regulations also apply onboard any aircraft under the jurisdiction of a Member State (e.g. registered in a Member State).