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Isle of Man

Registry: Isle of Man Aircraft Registry

Organisation: IOM CAA and Aircraft Registry

Prefix: M- | Author: Simon Williams

Website: www.iomaircraftregistry.com

Email: [email protected]

Phone: +44 (0)1624 682358

Isle of Man

Registry: Isle of Man Aircraft Registry

Organisation: IOM CAA and Aircraft Registry

Prefix: M- | Author: Simon Williams

Website: www.iomaircraftregistry.com

Email: [email protected]

Phone: +44 (0)1624 682358

Words by Simon Williams

Tell us a bit about the registry

As a Crown Dependency of the United Kingdom (UK), the Isle of Man falls within the UK’s ratification of the Chicago Convention. ICAO Standards and Recommended Practices are implemented in the Isle of Man and all information required under ICAO’s Universal Safety Oversight Audit Programme (USOAP) is maintained and updated.

The Isle of Man Aircraft Registry (IOMAR) core business is the registration, then subsequent safety regulatory oversight of private/corporate business jets and twin turbine helicopters.

As a carefully managed extension to core business, IOMAR also offers an efficient and appropriately tailored/robust registration service for ‘Transitional Aircraft’. This broadening of the IOMAR business portfolio has been increasingly successful over the past few years, has been resourced accordingly to meet response rates sought by industry and is supported by appropriate application of a relevant safety regulatory suite. More recently, we have enabled the operation of aircraft for the purposes of aerial work (“specialised services”).

How can I use my aircraft?

Private use: Yes. Registry Publication (RP) 68 sets out the legislative requirements, policy and guidance on the circumstances where receipt of valuable consideration and remuneration is permitted by private/corporate flights.

Corporate use: Yes. RP68 sets out the legislative requirements, policy and guidance on the circumstances where receipt of valuable consideration and remuneration is permitted by private/corporate flights.

Commercial air transport / aircraft charter: No. Aircraft registered in the Isle of Man are prohibited from undertaking commercial air transport. RP68 sets out the legislative requirements, policy and guidance regarding the prohibition of commercial air transport.

Aerial work:

Yes (subject to the issuance of an IOMAR approval). However, approval is not required for flights conducting aerial filming or imagery for which: - remuneration or valuable consideration is not provided for the service - the filming or imagery equipment is hand-held.

Clients holding a Certificate of Registration that was issued prior to the August 1st 2022 will be required to apply for the certificate to be reissued under the new Aircraft Registration and Marking legislation. To request a new Certificate of Registration please submit a completed Form 92 to [email protected]. Further guidance can be found in RP52.

Unmanned aerial vehicles: No.

What sort of aircraft do you consider?

  • Aeroplanes with MTOM of 5,700 kg or above and twin turbine-engine helicopters;
  • Aeroplanes with MTOM less than 5700kg but greater than 2730kg may be considered for registration on a case by case basis and at our discretion;
  • Aircraft of any weight owned by Isle of Man residents may be registered (Please note aircraft must be Type Certified and in the event that the owner subsequently ceases to be an Isle of Man resident it is expected that the aircraft would be re-registered elsewhere).

Further guidance is available on our website www.iomaircraftregistry.com/services/register-an-aircraft.

Are there weight restrictions?

Yes - see above.

Which aircraft type certificates are accepted?

The IOMAR directly accepts Type Certificates (and Supplementary Type Certificates) issued by:

  • EASA (Europe), or its member states
  • FAA (USA)
  • TCCA (Canada)
  • ANAC (Brazil) subject to the aircraft type design holding an issued TC from either EASA/FAA/TCCA
  • UK CAA (UK).

Are there age restrictions?

No.

Structuring requirements

Are aircraft registered in the name of aircraft operator or the aircraft owner?

Aircraft are registered in the name of the aircraft owner or charterer by demise. The registered owner must appoint an operator and the operator can be the same party.

Are there nationality requirements and if so what are they?

Any aircraft may use one of the following criteria:

  • The following persons are qualified to hold a legal or beneficial interest by way of ownership in an aircraft registered in the Isle of Man or in a share in such an aircraft: - The Crown in right of the Isle of Man, the UK or any part of the UK; - Commonwealth citizens; - Nationals of any European Economic Area (EEA) State or Switzerland; - British protected persons; - Bodies incorporated in some part of the Commonwealth or having their registered office, central administration or principal place of business in a part of the Commonwealth; or - Undertakings formed in accordance with the law of the Isle of Man, an EEA State or Switzerland and having their registered office, central administration or principal place of business within the Isle of Man, an EEA State or Switzerland.

Only “transitional aircraft” may use the following additional criteria (“transitional aircraft” are aircraft (typically airliners) which are awaiting a commercial lease or sale):

The following persons are qualified to hold a legal interest by way of ownership in a transitional aircraft registered in the Isle of Man or in a share in such an aircraft:

  • Bodies incorporated in or having their registered office, central administration or principal place of business in any of the States or territories listed below; or,
  • Undertakings formed in accordance with the law of and having their registered office, central administration or principal place of business within any of the States or territories listed below.
  • The States or territories referred to above are: - Hong Kong (Special Administrative Region); - Japan; - People’s Republic of China; - United States of America.

Exceptions for all aircraft:

  • If an unqualified person resides or has a place of business in the Isle of Man and holds a legal or beneficial interest by way of ownership in an aircraft or in a share in an aircraft, the IOMAR may register the aircraft in the Isle of Man if it is satisfied that the aircraft may otherwise be properly registered.
  • If an aircraft is chartered by demise to a person who qualifies under the above criteria, the IOMAR may, whether or not an unqualified person is entitled as owner to a legal or beneficial interest in the aircraft, register the aircraft in the Isle of Man in the name of the charterer by demise if it is satisfied that the aircraft may otherwise be properly so registered. Such an aircraft may remain registered during the continuation of the charter.

What are the typical structures used?

Limited companies.

Is there a requirement to have local directors of shareholders?

No. Aircraft do not need to be owned or imported into the Isle of Man in order to be registered by IOMAR.

Do you need to have a local office or physical presence to register an aircraft?

No.

Registration costs and service

Our guidance document for registration is RP1, Checklist for Registering Aircraft in the Isle of Man. This guide provides a detailed checklist for customers to use and includes links to all our application forms. All applications can be submitted electronically. Please contact the Registry at [email protected] as early as possible if you are considering registering an aircraft. This will enable our highly experienced team to guide you through the process and make the experience as efficient as possible.

What is the initial cost to register an aircraft?

Our Registry Services team can provide clients with an estimate to register an aircraft. The estimate will include reservation and registration of an out of sequence registration mark, four flight crew licence validations, approval of an MEL and a maintenance programme, and airspace approvals (including airspace operating manuals) for RVSM, NAT HLA (MNPS), RNAV 5 (B-RNAV, RNP 5). Other operational approvals are available which are not included in this estimate. The estimate does not include the surveyors travel time, expenses or airfare if applicable.

Here are some examples:

  • Cessna 525B (MTOM 6,291kg) – £7,918
  • Embraer EMB-135BJ (MTOM 22,500kg) – £11,118
  • Bombardier BD-700-1A11 (MTOM 41,957kg) – £15,018
  • Gulfstream GVI (MTOM 45,177kg) – £15,718
  • Boeing 737-700 (MTOM 77,564kg) – £22,218
  • Airbus A330-343 based on a MTOM of 233,000kg - £46,618*

* for aircraft with a greater MTOM than 200,000kg, the CoA fee is limited to that payable for an aircraft of 200,000kg*

What is the average time needed to register an aircraft?

Our current maximum timescale for registration, certificate of airworthiness issue and operating approvals is 15 working days, however we always endeavour to meet the needs of the customer and many projects are completed in a lesser timeframe. Registration alone can be completed in one working day. All certificates/documents are issued in digital format only, which reduces the time between registration/issue of operational certificates and the aircraft being able to operate.

An Export C of A is not required in order to register an aircraft in the IOM, subject to the aircraft holding a current C of A. In the absence of a current C of A or Export C of A, the IOMAR may specify alternative means of compliance.

What are the annual costs for aircraft registration?

There is no annual cost for registration. There will however, be an annual renewal Certificate of Airworthiness survey required. The estimate provided below is for the renewal Certificate of Airworthiness cost and surveyors work hours, it does not include the surveyor’s travel time, expenses or airfare, if applicable.

  • Cessna 525B (MTOM 6,291kg) - £2,748
  • Embraer EMB-135BJ (MTOM 22,500kg) – £4,668
  • Bombardier BD-700-1A11 (MTOM 41,957kg) – £7,008
  • Gulfstream GVI (MTOM 45,177kg) – £7,428
  • Boeing 737-700 (MTOM 77,564kg) – £11,328
  • Airbus A330-343 based on a MTOM of 233,000kg – £25,968*

* for aircraft with a greater MTOM than 200,000kg, the CoA fee is limited to that payable for an aircraft of 200,000kg

The Operations Specification is required to be renewed every three years.

How much does it cost to register a mortgage?

A Registry fee of £425.00 per mortgage applies.

Is there a cost to register a priority notice?

A Registry fee of £150.00 per priority notice applies.

Does the registry/aviation authority require a notarised/authenticated document to register an aircraft?

No. However, the aircraft registry application forms must be signed by a person authorised to do so on behalf of the applicant. Electronic copies of forms are accepted.

What continuing requirements are there to keep an aircraft registered?

Owners must continue to be qualified for an aircraft to remain on the Isle of Man Aircraft Register. Refer to RP 2 for further details.

Inspections and CoAs

Applies only to aircraft airworthiness surveys for issue of a Certificate of Airworthiness. There is no routine requirement for onsite flight operations inspections.

What are the requirements for a Certificate of Airworthiness?

Completion of aircraft registry application forms by competent persons (continuing airworthiness and operational knowledge will be needed for some forms). Initial and annual survey required to ensure airworthiness (on the day) and confirm conformity with Isle of Man civil aviation legislation throughout the last year (renewal).

Clients are offered the choice of either an attended on-site survey or a survey conducted remotely by digital means.

What is the inspection interval for a Certificate of Airworthiness / how often does the registry inspect aircraft?

Annual survey required for the renewal of the Certificate of Airworthiness, which can be renewed up to 60 days in advance of expiry without loss of validity.

What operational requirements are there?

The registered owner shall nominate an operator who is accountable for the safe operation, management and control of the aircraft. The operator is required to nominate competent personnel to the following specific roles:

  • Nominated Airworthiness Technical Representative (NATR) who has delegated responsibility for the full airworthiness management of the aircraft on behalf of the Operator and is the single point of contact for all matters of airworthiness with the IOMAR;
  • Flight Operations Representative (FOR) who has delegated responsibility for all flight operational matters on behalf of the operator and will be the primary point of contact with the IOMAR for this area.

The IOMAR does not mandate the use of a Continuing Airworthiness Maintenance Organisation (CAMO) but we do not object if an operator wishes to use the services of a CAMO.

A Certificate of Release to Service (CRS), otherwise known by ICAO as a “maintenance release”, may be issued by a person:

  • Acting in their duties as an employee of an organisation that holds a Part 145 approval issued by: - EASA; - FAA; - UK;
  • Holding of an aircraft maintenance engineer’s licence that has been validated by the IOMAR;
  • Who has been issued with an approved by the IOMAR.

A wide range of operational approvals are available upon presentation of evidence to show that the aircraft meets the relevant certification standards, and the operator has declared that the flight crews are suitably trained; and competent; and normal and abnormal/emergency procedures are in place; and meets the required operational criteria published in Registry Publication (RP) 4, Guidance to Operators.

The IOMAR does not issue flight crew licences. Flight crew must be issued with a certificate of validation of their flight crew licence. Validations are issued without restriction to a particular aircraft registration. The IOMAR validate licences issued by appropriate contracting states to the Chicago Convention and accepts the licensing/medical certificate variations/exemptions issued by the State of Licence Issuance unless specified otherwise.

How many airworthiness inspectors does the registry have?

At the time of writing, 17 airworthiness surveyors based at various international locations are available to appropriately support IOMAR operations. Resource levels are continually reviewed to ensure that appropriate international standards are maintained in a timely, efficient and customer focussed manner.

Where are the inspectors based?

The nature of the task has changed (as described above) and so the geographical location of surveyors is largely irrelevant now given the fundamental shift to remote surveys. It is worth noting that this change in approach has had the additional benefit of saving significant costs to the customer as international travel is no longer needed as part of the airworthiness process.

Financing and deregistration

Is there a requirement for a governing law of mortgage?

Mortgaging of Aircraft Order 1972 as applied to the Isle of Man.

What is most common choice of law for financings?

It is dependent on the preference of the lender and other factors. Typically, registered mortgages in the Isle of Man are governed by English, Isle of Man or New York law.

Can financiers file a priority notice of their interests?

Yes. A Registry fee of £150 applies.

Can financiers file a Deregistration Power of Attorney / Irrevocable Deregistration Power of Attorney (IDERA)?

Yes. The Cape Town Convention became operational on the Isle of Man from January 1st 2018.

Is there a public mortgage registry?

Yes. A search of the Isle of Man Register of Aircraft Mortgages can be requested online at https://ardis.iomaircraftregistry.com.

Is it easy for financiers to perfect a mortgage?

A completed Form 26 accompanied by a certified copy of the mortgage document is required to register a mortgage in the Isle of Man Register of Aircraft Mortgages. All documents can be submitted electronically. A fee of £425 applies.

How long is the period during which a moratorium be imposed in the event of a lessee or borrower insolvency?

Relevant and appropriate legal advice would need to be sought in this regard. The Aviation Business Directory lists a number of legal professionals based in the Isle of Man. https://www.iomaircraftregistry.com/about-us/isle-of-man-aviation-business-directory/

In the case of bankruptcy or insolvency are aircraft typically deemed to be part of the lessee’s property?

Legal advice would need to be sought in this regard. The Aviation Business Directory lists a number of legal professionals based in the Isle of Man. https://www.iomaircraftregistry.com/about-us/isle-of-man-aviation-business-directory/

Does the registry / aviation authority require a notarised/authenticated document to de-register an aircraft?

No.

What are the requirements for deregistration of an aircraft?

The following are required:

  • Form 11, Application for Deregistration signed by an authorised signatory of the registered owner, together with evidence of signing authority for such person; Electronic copies are accepted;
  • Discharge of registered mortgage(s) (if applicable);
  • Revoking of recorded IDERA (if applicable);
  • Release of Letter of Undertaking (if applicable);
  • Settlement of any outstanding registry fees prior to deregistration.

All documents and applications can be submitted electronically.

Registry Publication RP 12, Export Certificate of Airworthiness and De-registration of aircraft provides additional guidance.

What are the requirements for deregistration of mortgage?

A completed Form 28,Application for Discharge of Mortgage and a copy of a deed of release or equivalent document. A Registry fee of £300 per mortgage discharge applies. All documents can be submitted electronically.

Cape Town

Has the jurisdiction ratified the Cape Town Convention?

Yes. Further information available from https://www.iomaircraftregistry.com/services/cape-town-convention-and-idera/

What date did it come into effect?

January 1st 2018.

Which Cape Town declarations have been made?

The Annex to RP60 (Guidance on the Application of the Cape Town Convention to the Isle of Man) provides a table showing the options taken by the Isle of Man for each provision in the treaty, and how these can be traced to the content of the Regulation.

Which insolvency regime has been chosen?

Neither Option A nor Option B were selected, so Isle of Man insolvency legislation applies.

Are buyers eligible for the OECD Aircraft Sector Understanding discount?

We recommend seeking specialist legal advice on this issue.

Importing and exporting aircraft

Are there significant taxes or fees involved in importing an aircraft?

The aircraft does not need to be imported into the Isle of Man in order to be registered with IOMAR.

This subject is not an IOMAR aircraft registration issue, but one of VAT and customs. Specialist tax advice will be required. https://www.iomaircraftregistry.com/about-us/isle-of-man-aviation-business-directory/

Is an Export Certificate of Airworthiness, licence of permit required to export an aircraft?

Not from an Isle of Man aircraft registration perspective. Registry Publication RP 12, Export Certificate of Airworthiness and Deregistration of aircraft provides guidance on obtaining an Export Certificate of Airworthiness, if one is requested by the civil aviation authority of the aircraft’s new jurisdiction of registration.

Specialist tax advice should be sought in respect of any physical export of the aircraft.

How much does it cost to get an Export CoA and how long does it take to get one?

An Export CoA can be issued without the need for a survey. The issue date on the Export C of A will be the same as the CoA that was issued as the result of the last aircraft survey.

If a more recent issue date is needed on the Export CoA, a survey can be scheduled within seven working days from application.

There is a fee of £500 for an Export C of A, and if a survey is required, there will be: surveyor’s travel time; work hours; expenses; and airfares to be charged, where applicable.

Are there significant taxes or fees involved in exporting aircraft? See above.

Judgements and arbitration

Are any legislation or regulatory changes planned?

We have an ongoing project to update and enhance our civil aviation legislation. A new Aircraft Registration and Marking Order recently came into effect on August 1st 2022.

The following new Orders are anticipated:

  • Carbon Offsetting and Reduction Scheme for International Aviation Order – Q1 2023;
  • Airworthiness Order –2023/24;
  • Flight Operations Order –2023/24;
  • Aircraft Environmental Standards Order – 2023/24.

Aircraft Operating Certificates

Not applicable – aircraft registered in the Isle of Man are prohibited from undertaking Commercial Air Transport.

Official Guide to Aircraft Registration 2023

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