As a Russian citizen, am I allowed to go through theoretical or practical training, either in an aircraft or flight simulation training device (FSTD), or take examinations, skill tests or proficiency checks in accordance with Regulation (EU) No 1178/2011?
Answer
Training, testing and checking of Russian citizens is allowed if done for the purpose of operating a non-Russian-registered aircraft that is NOT owned or chartered(2) or otherwise controlled(1) by any Russian natural or legal person, entity or body.
If the intention of the applicant is to fly in Russia, at a Russian air carrier or Russian-registered aircraft or any non-Russian-registered aircraft that is owned or chartered or otherwise controlled by any Russian natural or legal person, entity or body, then such training, testing or checking is prohibited. Furthermore, the training, testing or checking cannot take place in Russia (c.f. Articles 3c(1) and 3d(1) of Regulation (EU) No 833/2014).
Note 1: The concept of ‘control’ is understood in the ‘economic’ or ‘financial’ sense and not in the ‘technical’ or ‘operational’ sense (cf. para 48 Judgement of the General Court Case T-233/22).
Note 2: The EU aviation law does not define ‘aircraft charter’. Member States authorities should apply the definition of ‘charter’ in accordance with their national legislation and relevant international agreements.