The fast pace of change in regards to airspace and restrictions with Russia, Europe and the UK is raising many questions. BBGA have been in constant dialogue with DfT and CAA  since the first NOTAM was released on Friday 25th February (noting scheduled aviation only).  This was quickly followed up with a secondary NOTAM to include Business Aviation.  As questions from our sector are risen we have endeavoured to gain clarity from DfT.  The FAQ below are being constantly updated.  Please contact BBGA on if you have further areas of concern that you wish clarified.

Can a Russian national still enter the UK?

Yes, they can still enter the UK but will need to do so using aircraft not registered with Russia or owned, chartered or operated by a person connected with Russia, and providing they have the correct permits and visas etc to enter the UK.

Can non-UK carriers use Russian airspace to fly to the UK?

It is for the Russian government to determine who can use its airspace. But provided the aircraft is not owned, operated, or chartered by a person connected with Russia, or registered in Russia then an aircraft using Russian airspace can also enter UK airspace.

What about Russian jets on the ground in UK...are they now effectively stranded?

Yes. It will not be possible for a Russian registered aircraft or aircraft owned chartered, or operated by a person connected with Russia, to depart a UK airport.

What is meant by “connected person”?

The restrictions apply to aircraft owned, chartered or operated by those connected to Russia. In the case of individuals this means persons who are ordinarily resident or located in Russia. • In the case of a business entity it means a company incorporated in, or with its HQ in, Russia.

We have members arranging ‘evacuation’ flights for businesses and individuals trying to leave Ukraine and Russia. If they charter a Russian registered aircraft to leave Moscow for example (only aircraft really that can depart there) our understanding is they can’t currently fly to the UK but can land elsewhere. Are there any exemptions for UK or non-Russian passport holders to do this and fly back to the UK?

This is ok as the UK regulations only cover UK airspace so don’t cover flights in other countries and there would be no problem doing staged flights; but ultimately the flight to the UK would need to be on a non-Russian operated/owned/chartered service.  

Also would there be a risk for the UK company chartering the Russian aircraft of breach of sanctions?

The penalty would be against the pilot and/or aircraft operator, usually the pilot. It is more likely to be a reputational risk for the charter company or aerodrome, but the existing regulations could change. We would expect UK charterers and aerodromes to take a cautious approach and to do what is proportionate to help to ensure that they are not linked to breaches of the regulations. We can’t comment on how Russia will enforce their own restrictions.

How do FBO’s / airports / brokers etc. identify clearly the Russian connection with many aircraft / operators who are registered in other jurisdictions but have ultimate ownership in Russia. If the passengers are travelling on non-Russian passports and operating on a Maltase registered aircraft it is very difficult to identify the Russian connection and apply the rules. How will UKBF handle this?

This should be compliant (unless there are reasonable grounds to assess a strong connection). Passengers are not affected (so Russian nationals can still travel to the UK as long as its on a non-russin aircraft/operator. The link needs to be between the operator or ownership of the aircraft being Russian (or have dual nationality). However, as above, FBOs, charterers, brokers etc should act prudently to ensure that the restrictions are being met, including doing some checks and asking about Russian nationality linked to ownership/chartering where relevant.