Published on April 24th, 2022 | by Mark Dwyer


35 Irish Registered Aircraft Impacted by Russian Sanctions

Main photo: Boeing 737-7CT, EI-GFR, is one of the aircraft affected by the sanctions. It has reportedly been re-registered as RA73268 in contravention of ICAO Article 18. As a result, the IAA has cancelled its certificate of airworthiness along with 34 other aircraft. Photo by Joe Heeney.

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.

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.

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.

(Click on the aircraft registration for the full details of each aircraft)

Mark (Registration)Aircraft name
(Type certificated model)
Serial No.
(Type certificate)
Certificate numberIssue date
Purported Russian dual registry marks*
EI-UNLBOEING 777-31228515UNL/COAN/0719/04/2021RA73279
EI-UNMBOEING 777-31228534UNM/COAN/0804/08/2021RA73280
EI-UNNBOEING 777-31228517UNN/COAN/0719/04/2021RA73281
EI-UNPBOEING 777-31228516UNP/COAN/0814/07/2021RA73282
EI-XLCBOEING 747-44627100XLC/COAN/0820/07/2021RA73283
EI-XLDBOEING 747-44626360XLD/COAN/0716/08/2021RA73284
EI-XLEBOEING 747-44626362XLE/COAN/0815/02/2021RA73285
EI-XLFBOEING 747-44627645XLF/COAN/0816/03/2021RA73285
EI-XLGBOEING 747-44629899XLG/COAN/0916/08/2021RA73287
EI-XLHBOEING 747-44627650XLH/COAN/0910/09/2021RA73288
EI-XLIBOEING 747-44627648XLI/COAN/0829/04/2021RA73289
EI-XLJBOEING 747-44627646XLJ/COAN/0916/03/2021RA73290
EI-XLMBOEING 747-41228028XLM/COAN/0720/07/2021RA73291
EI-XLPBOEING 777-31228531XLP/COAN/0714/07/2021RA73292
EI-FCHBOEING 737-83N32576FCH/COAN/0724/05/2021 
EI-TATCL-600-2B16 (604 VARIANT)5940TAT/COAN/0910/12/2021 
EI-ECMBOEING 737-86N32658ECM/COAN/0926/04/2021 
EI-GCVBOEING 737-7CT37088GCV/COAN/0705/01/2022 
EI-GESBOEING 777-31HER32706GES/COAN/0411/02/2021RA73274
EI-GETBOEING 777-31HER32709GET/COAN/0520/01/2022RA73275
EI-GEUBOEING 777-31HER32710GEU/COAN/0419/04/2021RA73276
EI-GFABOEING 777-31HER32715GFA/COAN/0526/08/2021RA73277
EI-GFBBOEING 777-31HER32730GFB/COAN/0526/08/2021RA73278
EI-GFRBOEING 737-7CT37421GFR/COAN/0505/01/2022
EI-GIHBOEING 737-86N32659GIH/COAN/0321/06/2021RA73264
EI-ECLBOEING 737-86N32655ECL/COAN/0926/04/2021
* 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.

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.

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About the Author

Mark is an airline pilot flying the Boeing 737 for a major European airline. In addition he is also a Type Rating Instructor, Type Rating Examiner and Base Training Captain on the B737. Outside of commercial flying Mark enjoys flying light aircraft from the smallest 3 Axis microlights up to heavier singles. He is also an instructor and EASA Examiner on single engines and a UK CAA Examiner. He flies the Chipmunk for the Irish Historic Flight Foundation (IHFF). Mark became the Chairman of the National Microlight Association of Ireland (NMAI) in 2013 and has overseen a massive growth in the organisation. In this role he has worked at local and national levels. In 2015, Mark won ‘Upcoming Aviation Professional Award’ at the Aviation Industry Awards sponsored by the IAA. Mark launched this website back in 2002 while always managing the website, he has also been Editor and Deputy Editor of FlyingInIreland Magazine from 2005 to 2015.

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