OFFICIAL GUIDE TO AIRCRAFT REGISTRATION - COUNTRY GUIDES

Aruba

Registry: The Aruban Civil Aviation Authority
Prefix: P4
Location: Caribbean
Country Status: Member of the Kingdom of the Netherlands

Aircraft

Weight restrictions: 5,700 kg (12,566.35 lb.)
Maximum Age: Aircraft manufactured before 1 January 1980
Aircraft Type Certificate: EASA, FAA, Transport Canada, & Brazil
Typical structure: Aruban A.V.V. or Domicile

Operation

Private use: Yes
Commercial Air Transport: Yes

Finance

Mortgage possible? Yes
Restriction Governing Mortgage law: A right of first mortgage of Aruba is established under Aruba law. Parties can choose the law that will govern the underlying loan documentation, which is typically NY or UK law
Priority notice: N/A
Public Registration: Yes Deregistration
Power of Attorney: Yes
Cape Town: Yes

Bahamas

Registry: The Bahamas
Prefix: C6-
Location: Atlantic Ocean
Country Status: Parliamentary democracy

Aircraft

Weight restrictions: None
Maximum Age: None, but must be a type that is acceptable to the Flight standards Inspectorate
Aircraft Type Certificate: AOC

Operation

Private use: Yes Commercial Air Transport: Yes

Finance

Mortgage possible? Yes, although there is no Mortgage Register held by the Department Civil Aviation they can nevertheless be notified and supplied with copy of the Deed of Mortgage
Restriction Governing Mortgage law: No.
Priority notice: Yes; first in time with respect to registration of a Deed of Mortgage
Public Registration: Registry of Records – Office of the Registrar General Deregistration
Power of Attorney: Yes or legal representative
Cape Town: No

Bermuda

Registry: Bermuda Department of Civil Aviation
Prefix: VP-Bxx and VQ-Bxx
Location: Atlantic Ocean
Country Status: United Kingdom Overseas Territory

Aircraft

Weight restrictions: none
Maximum Age: none
Aircraft Type Certificate: FAA, EASA and TC
Typical structure: UK, Commonwealth or EU national person, or incorporated bodies within the Commonwealth. Also undertakings registered within the European Economic Area plus incorporation in Bermuda.

Operation

Private use: Yes
Commercial Air Transport: Yes if Principle Place of Business is in Bermuda. ICAO 83bis agreements with Azerbaijan, Russia and Uzbekistan

Finance

Mortgage possible? Yes
Restriction Governing Mortgage law: No
Priority notice: Yes
Public Registration: No
Deregistration Power of Attorney: Yes
Cape Town: In process of enacting

Cayman Islands

Registry: Civil Aviation Authority of the Cayman Islands
Prefix: VP-C
Location: Caribbean
Country Status: British Overseas Territory

Aircraft

Weight restrictions: Maximum weight 5,700 kg (12566,35 lb.)
Maximum Age: None
Aircraft Type Certificate: FAA, Transport Canada, JAA & EASA
Typical structure: Commonwealth body incorporated, Limited Liability or Company Incorporated

Operation

Private use: Yes
Commercial Air Transport: Yes
Finance Mortgage possible? Yes
Restriction Governing Mortgage law: No
Priority notice: Yes
Public Registration: Yes
Deregistration Power of Attorney: Yes
Cape Town: Yes (as of 1st November 2015)

Dominican Republic

Registry: Yes
Prefix: HI
Location: Caribbean
Country Status: Sovereign state

Aircraft

Weight restrictions: None
Maximum Age: None
Aircraft Type Certificate: FAA and EASA
Typical structure: Individual and corporate body are acceptable

Operation

Private use: Yes
Commercial Air Transport: Yes

Finance

Mortgage possible? Yes
Restriction Governing Mortgage law: No
Priority notice: Yes
Public Registration: Yes
Deregistration Power of Attorney: Yes
Cape Town: No

Hong Kong

Registry: The Civil Aviation Department (“CAD”)
Prefix: B-H, B-K, B-L
Location: Asia
Country Status: Special Administrative Region of the People’s Republic of China

Aircraft

Weight Restrictions: Any aircraft other than “small aircraft” (i.e. aircraft weighing not more than 7 kg without its fuel) can be registered. Maximum Age Restrictions: None.

Aircraft Type Certificate: The CAD can issue type certificates subject to specific requirements. The CAD accepts and validates a certification approval granted by the Authority of the State of Design “as far as possible”. For aircraft type certificates issued by the EJAA, EASA or FAA, the Director-General of the CAD accepts that they are in compliance with the basic requirements of the Hong Kong airworthiness standards Typical structure: No typical structure. The persons entitled to hold a legal or beneficial interest in aircraft in Hong Kong comprise: (i) the mainland Chinese government or the Hong Kong government; (ii) Chinese citizens; (iii) Hong Kong permanent residents; or (iv) bodies incorporated in Hong Kong or other parts of the People’s Republic of China and having their principal place of business in Hong Kong or in other parts of China.

Operation

Private use: Yes
Commercial Air Transport: Yes

Finance

Mortgage possible? Yes
Restriction Governing Mortgage Law: Hong Kong does not maintain a register of aircraft mortgages or charges. Information about legal ownership, demise charter agreement, mortgages and charges are required at the time of registering the aircraft and the certificate of registration will include such information. If the mortgagor is a company incorporated or having a place of business in Hong Kong, an aircraft mortgage must be registered with the Companies Registry, subject to specific conditions, under the new Companies Ordinance. If the mortgagor is an individual, the aircraft mortgage must be registered as a bill of sale under the Bills of Sale Ordinance.


Priority notice: There is no register of aircraft mortgages in Hong Kong. Priority of aircraft mortgages will (i) be determined in accordance with the common law rules governing priority of mortgages and charges; (ii) depend on the type of mortgage, whether legal or equitable. Legal mortgages will have priority over earlier equitable encumbrances if the legal interest was acquired bona fide, for value and without notice of the previous equitable interests. Legal and equitable mortgages will rank inter se based on the order in which they were created.

Public Registration: No

Deregistration Power of Attorney: Deregistration powers of attorney are frequently issued but it is in the CAD discretion to decide whether an aircraft can be deregistered merely on the basis of a deregistration power of attorney.

Cape Town: Not ratified.

Isle of Man

Registry: Isle of Man Aircraft Registry
Prefix: M
Location: Europe
Country Status: British Crown Dependency

Aircraft

Weight restrictions: Maximum 5,700 kg (12566,35 lb.)
Maximum Age: None
Aircraft Type Certificate: Canada, USA, Brazil or EASA
Typical structure: Limited or Incorporated companies

Operation

Private use: Yes
Commercial Air Transport: No
Finance Mortgage possible? Yes
Restriction Governing Mortgage law: Mortgaging of Aircraft Older 1972
Priority notice: Yes
Public Registration: N/A
Deregistration Power of Attorney: No

Cape Town: No

 

Malta

Registry: Civil Aviation Directorate
Prefix: 9H
Location: Mediterranean
Country Status: Republic

Aircraft

Weight restrictions: Minimum 20 kg (44,09 lb.)
Maximum Age: None
Aircraft Type Certificate: None
Typical structure: Limited Liability Company

Operation

Private use: Yes
Commercial Air Transport: Yes
Finance Mortgage possible? Yes
Restriction Governing Mortgage law: Yes
Priority notice: No
Public Registration: Yes
Deregistration Power of Attorney: No
Cape Town: Yes

Panama

Registry: Panama
Prefix: HP
Location: Central America
Country Status: Republic

Aircraft

Aircraft which may be registered in Panama include:

  • aircraft owned by the Government of Panama;
  • aircraft involved in public transportation or carrying out remunerated aircraft operations which are owned or operated by Panamanian nationals, be they natural or juridical persons, legally authorised to operate;
  • aircraft involved in private operations which are owned or operated in Panama by Panamanian nationals or foreigners, be they natural or juridical persons.

There are two systems of aircraft registration in the Republic of Panama. The Civil Aeronautics Authority (Autoridad Aeronáutica Civil) maintains maintain an administrative registry of aircraft in Panama by means of the National Aeronautical Registry. In addition, there is an aeronautical section at the Public Registry Office, wherein all matters concerning the juridical status of aircraft are registered; namely proof of ownership, leases and encumbrances on aircraft, etc. in order to make them effective against third parties.
Weight restrictions: Weight restrictions will depend on the aircraft capacity, fuel, flight
Maximum Age: Maximum age requirements are not specifically addressed. Proper maintenance is required.
Aircraft Type Certificate: Certificates such as those of the United States and European Union are recognized.
Typical structure: Not specifically addressed in our regulations.

Operation

Private use: Private registration and use of aircraft is allowed, subject to obtaining the required operation certificates and permits from the Civil Aeronautics Authority.
Commercial Air Transport: Commercial air transport has nationality restrictions in terms of company ownership. A commercial exploitation permit for public air transport, issued by the Civil Aeronautics Authority, is required, as well as an operation certificate.

Finance

Mortgage possible? Law No.21 of 2003 expressly contemplates the possibility of granting a mortgage over an aircraft as a whole or covering parts only its spare parts, and the Law on Mortgages on Movable Goods further allows the sale thereof with retention of title. Mortgages in respect of aircraft have to be registered in the Aeronautical section of the Public Registry Office.
Restriction Governing Mortgage law: There are no limits to the types of obligations that may be secured so long as these are lawful obligations, nor as to who may be a mortgagee.
Priority notice: According to the Aeronautical Law, a credit secured by an aircraft mortgage will have priority over any other credit except for the national taxes that fall upon an aircraft. Nonetheless, Panama has acceded to the 1948 Geneva Convention on International Recognition of Rights in Aircraft.
This Convention imposes as compulsory liens the following:
  (a) Indemnification for assistance to, or salvage of, the aircraft.
  (b) Other expenses which are indispensable for the conservation of the aircraft.
These liens have priority over all other liens or credits, including the aircraft mortgage. Bearing in mind that ACC has the obligation to respect all international treaties and agreements to which Panama has acceded to, this clearly creates a conflict of laws which will have to be resolved by the Panamanian Judicial Branch once a case of this nature is presented.
Public Registration: A mortgage on an aircraft must be granted by public instrument in the Spanish language whenever the obligations secured are in excess of B./20,000.00 and must be registered at the Public Registry Office to affect third parties. Aircraft mortgages can also be filed at the National Aeronautical Registry. This filing, however, only serves as a notice to third parties. Thus, it will have no legal effects on the rights of the mortgagee. Apart from the registration of the mortgage as stated above no other registration or consents are required.
Deregistration Power of Attorney: Deregistration powers of attorney are available and effective in Panama.
Cape Town: Panama has also ratified the 2001 Cape Town Convention on International Interests in Mobile Equipment and its Protocols on Matters Specific to Aircraft Equipment, but with declarations under arts 39, 50, 53 and 54(2).

San Marino

Registry: San Marino Aircraft Registry
Prefix: T7-
Location: Europe
Country Status: Republic and autonomous state

Aircraft

Weight restrictions: NONE
Maximum Age: 1975
Aircraft Type Certificate: FAA, Transport Canada, Brazil ANAC and EASA.
Typical structure: Public Private Partnership

Operation

Private use: Yes
Commercial Air Transport: Yes

Finance

Mortgage possible? Yes
Restriction Governing Mortgage law: No, English and New York Law accepted
Priority notice: Not possible
Public Registration: Yes, in the San Marino aircraft register
Deregistration Power of Attorney: Yes
Cape Town: Yes, the Convention is in force since 1st January 2015.

Saudi Arabia

Registry: GACA
Prefix: HZ
Location: Middle East
Country Status: Kingdom

Aircraft

Weight restrictions: None
Maximum age: None
Aircraft Type: Certificate FAA
Typical structure: None

Operation

Private use: Yes
Commercial Air Transport: Yes
Finance Mortgage possible? No
Restriction Governing Mortgage law: Whilst the concept of aircraft mortgage is not specifically provided by Saudi Arabian law, it is possible to register a form of chattel mortgage as a right over an aircraft with the GACA
Priority notice: Save for ‘privileged debts’, the registration of a right over an aircraft with the GACA will provide priority from the date of entry
Public registration: No
Deregistration Power of Attorney: Original, notarised copy to be submitted to GACA
Cape Town: Yes.

Switzerland

Registry: Swiss Federal Office of Civil Aviation (FOCA)
Prefix: HB
Location: Europe (not a member of the European Union but of EASA)
Country Status: Confederation

Aircraft

Weight restrictions: None
Maximum Age: None
Aircraft Type Certificate: EASA
Typical structure: Swiss company or (subject to supply of Aircraft to a Swiss AOC operator) foreign company

Operation

Private use: Yes
Commercial Air Transport: Yes

Finance

Mortgage possible? Yes
Restriction Governing Mortgage law: Swiss law
Priority notice: No
Public Registration: Yes
Deregistration Power of Attorney: Recommended (but remains revocable under Swiss law)
Cape Town: No.

UAE

Registry: GCAA
Prefix: A6
Location: Middle East
Country Status: Federation

Aircraft

Weight restrictions: None
Maximum age: Only those aircraft with an age equal to or less than 20 years (calculated from the date of the first certificate of airworthiness) at the time of an application for a certificate of registration may be registered
Aircraft Type Certificate: EASA/FAA/TCCA
Typical structure: None

Operation

Private use: Yes
Commercial Air Transport: Yes
Finance Mortgage possible? No
Restriction Governing Mortgage law: Whilst the concept of aircraft mortgage stricto sensu is not specifically provided by the UAE law, it is possible to note a mortgage with the GCAA
Priority notice: N/A
Public registration: No
Deregistration Power of Attorney: Original, notarised copy to be submitted to the GCAA
Cape Town: Yes.

United Kingdom

Registry: United Kingdom (UK) Civil Aviation Authority (CAA)
Prefix: G
Location: Europe
Country Status: Unitary State

Aircraft

Weight restrictions: None
Maximum age: None
Aircraft Type Certificate: EASA
Typical structure: Company Limited with shares

Operation

Private use: Yes
Commercial Air Transport: Yes
Finance Mortgage possible? Yes
Restriction Governing Mortgage law: No
Priority notice: Yes -14 days
Public registration: Mortgages over Aircraft must be registered at the UK Register of Aircraft Mortgages.
Deregistration Power of Attorney: Original document. From 1 November 2015, when the International Interests in Aircraft Equipment (Cape Town Convention) Regulations 2015 (the “Regulations”) enters into force, an IDERA in the form annexed to the Aircraft Protocol may be submitted by a debtor to the CAA for recording. The Regulations oblige the CAA to honour a request for de-registration filed with it, subject to any applicable safety laws and regulations. The UK government has stated that the CAA will provide further guidance on how to register an IDERA.
Cape Town: This will enter into force in the UK on 1 November 2015, as implemented by the Regulations.

United States

Registry: FAA
Prefix: N
Location: North America
Country Status: Unitary State

Aircraft

Weight restrictions: None
Maximum age: None
Aircraft Type Certificate: Must be US type registered
Typical structure: Owner Trust Agreement

Operation

Private use: Yes
Commercial Air Transport: Yes

Finance

Mortgage possible? Yes
Restriction Governing Mortgage law: No restrictions
Priority notice: No
Public registration: FAA Registry/International Registry
Deregistration Power of Attorney: If Cape Town registered and IDERA is filed registry will honour only if the authorised party has made the request & Registry notifies country of export of cancellation
Cape Town: Yes.

Information provided by Corporate Jet Investor.