The Russian government has elected to pursue the removal of the International Civil Aviation Organization’s (ICAO) “red flag” from the country’s civil aviation. The ICAO assigned Russia the “Significant Safety Concern” (SSC) status in 2022, emphasizing the gravity of aviation safety concerns, particularly those associated with the dual registration of aircraft. The documents, that Rosaviatsiya (Russia’s Federal Air Transport Agency) has submitted, argue that the decision was politically motivated. They will be forwarded to the ICAO. Additionally, letters are being prepared for aviation authorities in friendly countries.
The reasons for the International Civil Aviation Organization’s concerns regarding Russia
According to the Russian media outlet Izvestia, Rosaviatsiya is in the process of removing the negative SSC status that the ICAO imposed in 2022 as a result of aircraft dual registration. The agency has put together proposals to engage in a dialogue with the ICAO regarding this matter. The Russian Ministry of Transport received analytical materials in 2024 that argued that the SSC designation was politically influenced and did not adhere to ICAO standards.
There should be only one state registration for aircraft. Nevertheless, dual registration was the result of the US and European sanctions on Russia. The majority of Russian civilian aircraft were registered and leased in Bermuda. When sanctions came into effect, Bermudian aviation authorities revoked airworthiness certificates and demanded the return of leased aircraft. Consequently, the Russian authorities re-registered them domestically, thereby contravening the ICAO conventions. Rosaviatsiya subsequently assumed responsibility for airworthiness supervision.
The ICAO demanded the cessation of dual registration in mid-2022, following an audit. ICAO designated the “red flag” status to Russia in September 2022 when it failed to comply. By operating aircraft without legitimate airworthiness certificates, Russia violated Articles 18, 19, 29, and 31 of the Chicago Convention on Civil Aviation, according to the ICAO Council.
The highly politicized term “red flag” was derived from the prevalent dual registration of Russian airline aircraft. SSC status does not impose restrictions on a country; instead, it alerts ICAO partners to industry-related issues. ICAO has identified Bhutan, the Democratic Republic of the Congo, Liberia, Ecuador, and Zimbabwe as countries with “red flags.” These are linked to their aircraft nationality marks, which are alphanumeric codes assigned to each member state of ICAO.
Rosaviatsiya has been trying to modify the SSC status since 2022. The sixth ministerial conference of the “Group of Friends in Defense of the UN Charter” during the 79th UN General Assembly on September 27, 2024, resulted in significant progress. A political declaration that criticized restrictions on civil aviation was ratified by several states that are friendly to Russia. This coalition comprises the following countries: Russia, Algeria, Belarus, Bolivia, Venezuela, Zimbabwe, Iran, China, North Korea, Cuba, Laos, Mali, Nicaragua, Palestine, Saint Vincent and the Grenadines, Syria, Equatorial Guinea, and Eritrea.
Draft letters regarding the SSC status have been prepared by Rosaviatsiya and may be sent to sympathetic governments upon approval by the Russian Ministry of Transport. Additionally, Rosaviatsiya has initiated discussions with North Korea’s aviation administration regarding SSC status. Furthermore, efforts are currently underway to remove Russian aircraft from foreign registries. By the end of 2024, domestic airlines acquired 216 Russian aircraft that had resolved their dual registration. This development will enable these aircraft to operate on a global scale.
The re-registration procedure was accomplished through collaboration with foreign aviation authorities and lessors, as per Rosaviatsiya. Nevertheless, approximately 300 aircraft in Russia continue to operate with dual registration.
The Consequences of Eliminating the “Red Flag”
There has been no increase in incidents involving dually registered aircraft in Russia, and the dual registration does not directly impact flight safety. The data from Rosaviatsiya for 2023 and 2024 suggests that the accident rate per million regular commercial flights in Russia for aircraft over 5,700 kg was 1.27 in 2024, which is lower than the global average of 1.87 set by the ICAO.
Although the “red flag” has minimal direct impact on civil aviation, it exerts political pressure on Russia’s partners. Nevertheless, sanctions have had a substantial effect on the industry. Consequently, the removal of the SSC status is a long-term endeavor that may become more pertinent if sanctions are relaxed.
The removal of the “red flag” has the potential to lower the cost of insurance for passengers, personnel, and aircraft. It would also reduce operational expenses for all airlines operating in Russian airspace, including foreign carriers, by reducing perceived flight safety hazards. Such measures could indirectly reduce ticket prices or enhance airline profitability.
The withdrawal of the SSC status could also affect the policies of airlines that have restricted flights to Russia due to safety concerns, as well as the decisions of ICAO member states regarding air traffic with Russia.
Nevertheless, it is improbable that there will be substantial progress in the relationship with ICAO officials until the geopolitical tensions subside. However, the process of deregistering aircraft from the Bermuda registry has yielded significant gains.
Russia must first eliminate the formal justification for the “red flag,” which is dual aircraft registration. This procedure, which is frequently referred to as the “de-Bermudization” of the Russian fleet, is still in progress.
Given that European and North American airlines have a vested interest in reopening Russian airspace, any future sanctions relief may also start with aviation. These airlines have been compelled to adopt lengthier alternative routes as a result of the closure of Russian airspace, which has resulted in flight times that are several hours longer.
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