The sanctions imposed by the European Union on Russia restrict the exercise of pilot privileges of Russian nationals in the EU. However, the new amendment to the Regulation, which entered into force on 25 June 2024, exempts private flights when the aircraft has a maximum seating capacity of no more than 4 persons and a maximum take-off mass of no more than 2000 kg. Flight training and proficiency checks for private pilot licences and related ratings on such aircraft are also permitted if the person does not intend to fly in Russia or otherwise use their skills for the benefit of Russia.
On 24 June 2024, the Council of the European Union adopted Regulation (EU) 2024/1745 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine. Article 3d, paragraph 1 prohibits any Russian registered aircraft or any aircraft which is owned or chartered, or otherwise controlled by any Russian person, entity or body, to land in, take off from or overfly the territory of the Union. The new amendment to the Regulation relaxes the flight ban by allowing Russian nationals and dual nationals to fly privately in the Union airspace on aircraft that have a maximum seating capacity of no more than 4 persons and a maximum take-off mass of no more than 2000 kg.
Flight training and proficiency checks for private pilot licences and related ratings with Union training providers are also permitted on the aforementioned aircraft. However, the amendment to the Regulation does not cover Article 3c, paragraph 1 which prohibits, for example, the sale, supply, transfer and export of products and technology suitable for use in aeronautics and the space industry in Russia. Paragraph 4 of the same Article prohibits technical assistance related to the use of such products, including training. For this reason, Traficom continues to require Russian nationals and dual nationals to sign a declaration under oath, in which they undertake not to use their licence in Russia. The wording of the declaration for private pilots will be updated to reflect the new amendment.
In the future, Russian nationals or dual nationals will be permitted to fly an aircraft owned by them or by another Russian national as private pilots for recreational purposes in the EU, as long as the aircraft meets the applicable seating capacity and mass limits. Private pilots may also fly Russian registered aircraft in the EU.
On the basis of a judgment by the European Court of Justice in the case T-233/22, Islentyeva v Council, it has already been permitted to fly an aircraft rented from a flying club, for example. Parachuting flights, forest fire patrol flights and aero-tow flights in the name of a flying club are also allowed, as well as acting as a flight instructor under an EU training organisation.
Declaration (External link)
(the declaration form for exempted private pilots will be updated later, please contact Traficom)
The national competent authority referred to in the EU sanctions regulations is the Ministry for Foreign Affairs. The implementation of the sanctions in different administrative sectors is handled by ministries, National Enforcement Authority Finland, Finnish Customs, the National Bureau of Investigation, the Financial Supervisory Authority, the Finnish Border Guard and the Regional State Administrative Agency for Southern Finland, among others.
FURTHER INFORMATION
- EU law database EUR-Lex: Sanctions Regulation (External link)(EU) 833/2014 (consolidated version)
- Amendment (EU) 2024/1745 (External link)
- European Union Aviation Safety Agency (EASA): Aircrew training and licensing - Restrictive measures Russia, FAQ (External link)
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