IAA Website - Monday, May 16, 2022 8:05 AM

The European Union adopted a comprehensive set of restrictive measures in response to Russia’s invasion of Ukraine in February 2022.  Those measures relate also to the aviation sector and contain in particular a comprehensive ban on the export of goods and technology suited for use in aviation and the prohibition of provision of technical assistance and other related services in relation to aviation goods and technology to persons, entities or bodies in Russia or for use in Russia. The measures adopted by the EU also ban Russia’s air carriers and aircraft from flying into, over or out of the territory of the EU.

A comprehensive summary of the restrictive measures is available on the EASA website.

This dedicated area on the EASA website provides information for the aviation community about the impacts of those restrictive measures on the activities regulated under the aviation safety rules falling under Regulation (EU) 2018/1139. It also provides information about the actions taken by EASA and the EU competent authorities in implementing the restrictive measures and provides answers to some of the frequently asked questions: https://www.easa.europa.eu/the-agency/faqs/common-issues-restrictive-measures-russia 

The information contained on the EASA website is of a technical nature and complements the information already available on the websites of European Institutions and the competent authorities for the sanctions in Ireland, namely:

Irish Airspace

In response to the measures adopted, the IAA has restricted Russia’s air carriers and aircraft from flying into, over or out of Irish airspace.

Irish Registered Aircraft operated by Russian Airlines

As a further consequence of the sanctions issued by the European Union, Canada and the United States of America, Russian airlines operating aircraft registered on the Irish aircraft register no longer have access to the current approved airworthiness and operational data from the type certificate holder, which is required for the continuing safe operation of these aircraft. As the airworthiness of these aircraft cannot be assured, the Irish Aviation Authority has cancelled the certificate of airworthiness for these aircraft. The full details of the Direction contained in IAA Aeronautical Notice A.114 is available here. The list of aircraft impacted is repeated below.

The registered owners and operators have been directed to remove the certificate of airworthiness issued by the Authority and that the aircraft shall not be flown without prior permission of the IAA.

It has been noted that some of these Irish registered aircraft continue to operate in contravention of the ICAO Convention on International Civil Aviation (the Convention) Article 31 - Certificates of airworthiness and appropriate Irish legislation. Article 33 of the Convention - Recognition of certificates and licenses of the Convention requires that the ICAO Contracting States recognize the Certificate of Airworthiness issued by the State of Registry as valid.

It is also noted that the Russian Federation has re-registered foreign registered aircraft in the Russian Federation without the aircraft first being deregistered by the existing State of Registry. A number of Irish registered aircraft have already been re-registered in Russia. Article 18 of the Convention - Dual registration allows the transfer of registration, but dual registration is strictly forbidden. 

The IAA will only deregister aircraft on request from the registered owner, in accordance with relevant Irish legislation and procedures.

This also ensures an aircraft is not deregistered until a registered mortgage or ICAO Cape Town - irrevocable deregistration and export request authorisation (IDERA) is discharged.

The IAA request all ICAO Contracting States to comply with the obligation to carry out effective surveillance over foreign operators flying in their territory, in order to ensure that they do so in full compliance with applicable SARPs,  and to take appropriate action when necessary to preserve safety (Resolution A36-6, clauses 1 and 2). Articles 11, 16, and 29 of the Chicago Convention are key in this regard. The IAA request all ICAO contracting States to restrict these aircraft from flying into, over or out of their airspace. The flights should only be allowed after prior consultation with the IAA.

Irish Registered Aircraft whose Certificate of Airworthiness has been cancelled

Mark (Registration) Aircraft name
(Type certificated model)
Serial No.
(Type certificate)
Certificate number Issue date
(dd/mm/yyyy)
Purported Russian dual registry marks*
EI-UNLBOEING 777-312 28515 UNL/COAN/07 19/04/2021 RA73279
EI-UNM BOEING 777-312 28534 UNM/COAN/08 04/08/2021 RA73280
EI-UNN BOEING 777-312 28517 UNN/COAN/07 19/04/2021 RA73281
EI-UNP BOEING 777-312 28516 UNP/COAN/08 14/07/2021 RA73282
EI-XLC BOEING 747-446 27100 XLC/COAN/08 20/07/2021 RA73283
EI-XLD BOEING 747-446 26360 XLD/COAN/07 16/08/2021 RA73284
EI-XLE BOEING 747-446 26362 XLE/COAN/08 15/02/2021 RA73285
EI-XLF BOEING 747-446 27645 XLF/COAN/08 16/03/2021 RA73285
EI-XLH BOEING 747-446 27650 XLH/COAN/09 10/09/2021 RA73288
EI-XLI BOEING 747-446 27648 XLI/COAN/08 29/04/2021 RA73289
EI-XLJ BOEING 747-446 27646 XLJ/COAN/09 16/03/2021 RA73290
EI-XLM BOEING 747-412 28028 XLM/COAN/07 20/07/2021 RA73291
EI-XLP BOEING 777-312 28531 XLP/COAN/07 14/07/2021 RA73292
EI-FCH BOEING 737-83N 32576 FCH/COAN/07 24/05/2021  
EI-TAT CL-600-2B16 (604 VARIANT) 5940 TAT/COAN/09 10/12/2021  
EI-ECM BOEING 737-86N 32658 ECM/COAN/09 26/04/2021  
EI-FNX A330-243 283 FNX/COAN/07 30/06/2021  
EI-FSE A330-243 293 FSE/COAN/05 19/05/2021  
EI-FSF A330-243 295 FSF/COAN/09 29/03/2021  
EI-GCV BOEING 737-7CT 37088 GCV/COAN/07 05/01/2022  
EI-GCZ A330-223 0739 GCZ/COAN/05 19/01/2022  
EI-GES BOEING 777-31HER 32706 GES/COAN/04 11/02/2021 RA73274
EI-GET BOEING 777-31HER 32709 GET/COAN/05 20/01/2022 RA73275
EI-GEU BOEING 777-31HER 32710 GEU/COAN/04 19/04/2021 RA73276
EI-GFA BOEING 777-31HER 32715 GFA/COAN/05 26/08/2021 RA73277
EI-GFB BOEING 777-31HER 32730 GFB/COAN/05 26/08/2021 RA73278
EI-GFR BOEING 737-7CT 37421 GFR/COAN/05 05/01/2022
EI-GIH BOEING 737-86N 32659 GIH/COAN/03 21/06/2021 RA73264
EI-GOT A330-323 1021 GOT/COAN/03 19/05/2021  
EI-GPJ A330-323 0965 GPJ/COAN/03 03/09/2021  
EI-GVH A330-243 0456 GVH/COAN/02 19/01/2022  
EI-GWF A330-323 1265 GWF/COAN/01 20/05/2021  

 

In contravention to the ICAO Convention, it is the IAA’s understanding that Russia has assigned mark to the Irish registered aircraft as listed above.