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:
- The Central Bank of Ireland - https://www.centralbank.ie/regulation/how-we-regulate/international-financial-sanctions
- Department of Foreign Affairs - https://www.dfa.ie/our-role-policies/ireland-in-the-eu/eu-restrictive-measures/
- Department of Enterprise, Trade and Employment: https://enterprise.gov.ie/en/What-We-Do/Trade-Investment/Export-Licences/Sanctions/
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
(Type certificated model)
|Purported Russian dual registry marks*
|CL-600-2B16 (604 VARIANT)
* 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.