The European Business Aviation Association (EBAA) has today updated its members with the following advice on maintaining Russian-owned aircraft

The European Commission has come back to the EBAA with a small but important revision to what they said earlier. The interpretation of Art 3c of Reg 833/2014 with regards to maintenance has been debated by their legal services and they have now a more nuanced reading of Art 3c.

The main text you will find here, but essentially there is now a possibility to do maintenance on a Russian owned aircraft that is based outside Russia and which is not intended for use in Russia. The latter criterion (use in Russia) is of course inevitably something of a judgement call, but a non-Russian registered aircraft, that has a history of mainly flying outside Russia would qualify.

Of course, they still would not be allowed to fly because of Art 3d flight ban, but at least preservation service could be performed.

In case of doubt or uncertainty, we invite you to contact your authorities or to get in touch with us so that we can help you operate safely.

Note that the hyperlink to the EBAA website in this quote provides further details on how Russian aircraft can be handled in the light of the sanctions imposed by various countries and country groups.

As always, this should not replace seeking legal advice from appropriately qualified persons.