(fra departementets EØS-notat, sist oppdatert 9.12.2025)

(1) Commission Regulation (EC) No 474/2006 (2) establishes the list of air carriers, which are subject to an operating ban within the Union.

(2) Certain Member States and the European Union Aviation Safety Agency (‘the Agency’) communicated to the Commission, pursuant to Article 4(3) of Regulation (EC) No 2111/2005, information that is relevant for updating that list. Third countries and international organisations also provided relevant information. Based on the information provided, the list should be updated.

(3) The Commission informed all air carriers concerned, either directly or through the authorities responsible for their regulatory oversight, about the essential facts and considerations, which would form the basis of a decision to impose an operating ban on them within the Union, or to modify the conditions of an operating ban imposed on an air carrier which is included in the list set out in Annex A or Annex B to Regulation (EC) No 474/2006.

(4) The Commission gave the air carriers concerned the opportunity to consult all relevant documentation, to submit written comments and to make an oral presentation to the Commission and to the EU Air Safety Committee.

(5) Within the framework of Regulation (EC) No 2111/2005 and Commission Delegated Regulation (EU) 2023/660 (3), the Commission informed the EU Air Safety Committee about the ongoing consultations with the competent authorities and air carriers of Angola, Armenia, and Kyrgyzstan. The Commission also informed the EU Air Safety Committee about the aviation safety situation in Congo Brazzaville, Iraq, Mali, Pakistan, Suriname, Syria, Tanzania, Tunisia and Uzbekistan.

(6) The Agency informed the Commission and the EU Air Safety Committee about the technical assessments conducted for the initial evaluation and the continuous monitoring of Third Country Operator (‘TCO’) authorisations, issued pursuant to Commission Regulation (EU) No 452/2014 (4).

(7) The Agency also informed the Commission and the EU Air Safety Committee about the results of the analysis of ramp inspections carried out under the Safety Assessment of Foreign Aircraft programme (‘SAFA’), in accordance with Commission Regulation (EU) No 965/2012 (5).

(8) In addition, the Agency informed the Commission and the EU Air Safety Committee about the technical assistance projects carried out in third countries affected by an operating ban pursuant to Regulation (EC) No 474/2006. Furthermore, the Agency provided information on the plans and requests for further technical assistance and cooperation to improve the administrative and technical capability of civil aviation authorities in third countries with a view to helping them assure compliance with applicable international civil aviation safety standards. Member States were invited to respond to such requests on a bilateral basis in coordination with the Commission and the Agency. In that regard, the Commission reiterated the usefulness of providing information to the international aviation community, particularly through the International Civil Aviation Organisation's (‘ICAO’) Aviation Safety Implementation Assistance Partnership tool, on technical assistance to third countries provided by the Union and Member States to improve aviation safety around the world.

(9) EUROCONTROL provided the Commission and the EU Air Safety Committee with an update on the status of the SAFA and TCO alarming functions, including statistics about alert messages for banned air carriers.

Union air carriers

(10) Following the Agency’s analysis of information resulting from ramp inspections carried out on the aircraft of Union air carriers, as well as standardisation inspections carried out by the Agency, and complemented with information stemming from specific inspections and audits carried out by national aviation authorities, Member States took certain corrective and enforcement measures, and informed the Commission and the EU Air Safety Committee about those measures.

(11) Member States reiterated their readiness to act, as necessary, in the event that pertinent safety information indicates imminent safety risks resulting from non-compliance by Union air carriers with relevant safety standards.

Air carriers from Angola

(12) In July 2007, TAAG Angola Airlines was included in Annex A to Regulation (EC) No 474/2006 by Commission Regulation (EC) No 787/2007 (6). In November 2008, all air carriers certified in Angola were included in Annex A to Regulation (EC) No 474/2006 by Commission Regulation (EC) No 1131/2008 (7). In July 2009, TAAG Angola Airlines was moved to Annex B to Regulation (EC) No 474/2006 by Commission Regulation (EC) No 619/2009 (8). In April 2019, by Commission Implementing Regulation (EU) 2019/618 (9), TAAG Angola Airlines was removed from Annex B to Regulation (EC) No 474/2006 and Heli Malongo from Annex A to Regulation (EC) No 474/2006.

(13) TAAG Angola Airlines was placed in the first quarter of 2025 under intensified surveillance by the Agency pursuant to Regulation (EU) No 452/2014, following serious unresolved compliance issues in Operations, Airworthiness, SMS and Quality system areas, identified through continuous monitoring activities by the Agency. In this context, the Agency conducted an audit at the premises of TAAG Angola Airlines on 3 and 4 April 2025, which revealed fifteen Level 2 findings constituting the root cause of a Level 1 finding related to non-compliance with the applicable requirements of Annex 1 (Part-TCO) to Regulation (EU) No 452/2014. The audit further showed that the oversight activities conducted by the the National Civil Aviation Authority of Angola (‘ANAC’) were incomplete and below the relevant international safety standards.

(14) On 30 April 2025, the Agency notified the air carrier of its intention to suspend TCO Authorisation No. EASA.TCO.AGO.0001 and requested immediate mitigation measures and corrective actions by 14 May 2025. TAAG Angola Airlines subsequently submitted a Corrective Action Plan (‘CAP’) that was accepted by the Agency, leading to the lifting of the suspension process on 23 June 2025.

(15) In June 2025, in response to a request from ANAC to reengage with the Commission on the status of aviation safety oversight in Angola, the Commission asked ANAC to provide detailed information on its organisation, functioning, and the surveillance activities conducted on the air carriers it has certified as well as on the follow-up to the recommendations set out in the Agency Technical Assistance Report of December 2020.

(16) ANAC did not provide the requested information but instead sent its Comprehensive Safety Oversight Enhancement Project (‘CSOEP’) Master Plan to the Commission in July 2025, outlining reforms to restructure ANAC. However, the information provided was insufficient to allow a full assessment of the current state of safety oversight in Angola, as it did not include the documentation and clarifications necessary to evaluate the basis for the issuance and continued validity of Air Operator Certificates, or the interim oversight measures pending implementation of the CSOEP Master Plan. Consequently, the Commission submitted a new request for documentation in August 2025.

(17) The response letter transmitted by ANAC to the Commission in October 2025 once again did not contain the information requested in the Commission’s letters of June and August 2025. Consequently, the Commission sent a new letter on 7 November 2025, urging ANAC to submit part of the previously requested information before the upcoming EU Air Safety Committee meeting and to provide the remaining details by 15 January 2026. Additionally, the Commission invited ANAC to a technical meeting scheduled for February 2026 to discuss actions undertaken by ANAC within the framework of the CSOEP and to reassess, as necessary, the decision adopted by the European Commission in Implementing Regulation (EU) 2019/618 to remove TAAG Angola Airlines and Heli Malongo from the Union list of air carriers subject to an operating ban.

(18) In response to the latest request from the Commission, ANAC provided, in its letter of 13 November 2025, certain general information previously sought, including elements on its organisational structure and functioning and on the air carriers that it has certified. Although ANAC indicates that its strategy is based on a dual approach, combining vigilant control under the current system with a long-term modernisation effort, the information submitted does not, at this stage, provide sufficient assurance regarding the present compliance of its activities with international safety standards, in particular as regards the issuance and continued validity of certificates and the related continuous oversight activities. These matters will be included on the agenda of the technical meeting scheduled for February 2026, for which ANAC has confirmed its participation.

(19) In accordance with the common criteria set out in the Annex to Regulation (EC) No 2111/2005, the Commission considers that at this time there are no grounds for amending the list of air carriers, which are subject to an operating ban within the Union with respect to air carriers certified in Angola.

(20) Member States should continue verifying the effective compliance of air carriers certified in Angola with the relevant international safety standards through prioritisation of ramp inspections of those air carriers, pursuant to Regulation (EU) No 965/2012.

(21) Further action by the Commission should be taken as necessary, in accordance with Regulation (EC) No 2111/2005, if any relevant safety information reveals imminent safety risks resulting from non-compliance with the relevant international safety standards.

Air carriers from Armenia

(22) In June 2020, all air carriers certified in Armenia were included in Annex A to Regulation (EC) No 474/2006, by Commission Implementing Regulation (EU) 2020/736 (10).

(23) As a follow-up to the EU Air Safety Committee deliberations in May 2025, experts from the Commission, the Agency and Member States conducted a Union on-site assessment visit in Armenia from 1 to 5 September 2025 at the Civil Aviation Committee of Armenia (‘CAC’). The Union on-site assessment visit included a sample assessment of two air carriers certified in Armenia, namely Armenia Airways and Shirak Avia.

(24) The Union on-site assessment visit focused its activities on the CAC in view of its role and responsibility for the safety oversight activities of the air carriers certified in Armenia.

(25) The assessment confirmed that the CAC has taken clear steps towards building a functioning safety oversight system aligned with the relevant international safety standards. The CAC is engaged in continuous improvement initiatives and has demonstrated willingness to address identified gaps.

(26) Armenia has made notable progress in developing a comprehensive secondary aviation legislation framework aligned with ICAO Annexes and key elements of the EU aviation safety rules across all core domains. To further build on this progress, continued efforts are needed to ensure consistent maintenance and timely implementation of the latest ICAO and EU amendments. In particular, the systematic notification and publication of differences remains outstanding. Also, Armenia does not have national flight and duty time limitations (‘FTL’) rules for helicopter operations. Strengthening these processes will help ensure full and up-to-date compliance with relevant international safety standards.

(27) The CAC has established the key organisational functions required for safety oversight, supported by motivated staff. Further refinement is needed to ensure alignment between the approved organigram and actual reporting lines. Moreover, additional clarification is required regarding the chain of command in situations where both the Chair and the Deputy Chair are absent. Although state-level provisions allow the Minister to designate a temporary lead, obtaining such empowerment at the moment of need may delay urgent enforcement decisions, for example identifying who is authorised to issue a grounding order for an aircraft with significant safety deficiencies.

(28) The CAC has implemented certification and surveillance activities in the area of air operations, and introduced elements of risk-based oversight. The assessment of the recent oversight activities conducted by CAC demonstrate that the current processes do not always ensure an adequate verification of air carrier compliance. For example, an Electronic Flight Bag operational evaluation phase was approved, although essential information on hardware, software, demonstration plan and required tests had not been provided. While the checklists used had been formally completed, the verification revealed that key requirements had not been assessed in practice. This indicates that the use of oversight tools does not yet ensure a systematic and reliable assessment of operational safety. The FTL checklists dedicated to airplanes was used for the certification of helicopter air carrier.

(29) In the area of Flight Operations, substantial progress is still required. Certificates and approvals continue to be granted without ensuring that air carriers have demonstrated compliance with the appropriate safety standards, due to inconsistent oversight practices and the absence of complete regulatory provisions. Combined with limited enforcement powers, delayed or cancelled surveillance activities, and insufficient access to operational documentation, these shortcomings significantly reduce the CAC’s ability to ensure continuous and effective safety control over air carriers.

(30) In the area of airworthiness, the CAC demonstrated solid technical oversight capabilities and a proactive approach. The development of a risk-based oversight method is positive, although internal procedures and compliance monitoring should continue to be strengthened to ensure that all approvals and certificates are issued in full alignment with the relevant international safety standards.

(31) The Union assessment team carried out an on-site visit at Armenia Airways on 3 September 2025.

(32) Armenia Airways has established the core elements of its Safety Management and Compliance Monitoring Systems. However, both remain largely procedural. The Safety Management Manual is generic and not fully adapted to the air carrier’s activities, and inconsistencies exist between safety and quality policies. Compliance monitoring is not fully integrated into daily operations.

(33) Improvements are needed in flight crew training oversight and operational documentation. While relevant systems and procedures are in place, the electronic platform used to track training validity contained incorrect data and sampling showed that some elements of the air carrier conversion course had not been fully delivered. In addition, the Operations Manual and Minimum Equipment List (‘MEL’) require further customisation. Aircraft documentation was not always completed in full accordance with procedures, with missing commander signatures and fuel entries in Technical Log Books, outdated charts, and incorrect standard passenger masses used in load sheets.

(34) By contrast, maintenance and continuing airworthiness arrangements at Armenia Airways were assessed as satisfactory, with no major issues observed.

(35) The Union assessment team carried out an on-site visit at Shirak Avia on 3 September 2025.

(36) Shirak Avia has established the main elements of Safety Management and Compliance Monitoring Systems. However, they are still largely procedural and insufficiently embedded in operational practice. The Safety Management Manual is generic, and the Management of Change process does not ensure systematic mitigation of safety risks. Regulatory references in the Compliance Monitoring Manual lack precision.

(37) Deficiencies were identified in operational documentation and control. The Operations Manual and MEL contain outdated and un-customised content, with ineffective document control leading to multiple versions of the same MEL. Operational planning and fuel management procedures were not consistently applied, including incorrect contingency fuel calculations and incomplete operational flight plan updates.

(38) Maintenance and continuing airworthiness arrangements at Shirak Avia were found satisfactory, with no significant deficiencies identified.

(39) On 27 October 2025, the CAC submitted to the Commission a package of CAPs, together with proof of implementation for certain actions, in response to the observations made during the Union’s on-site assessment visit. The CAPs covered the domains of legislation and organization, the State Safety Programme, personnel licensing, airworthiness, and air operations.

(40) While the CAPs provide follow-up and a commitment to addressing the observations raised, it was noted that most of them either omitted or insufficiently elaborated on the Root Cause Analysis (‘RCA’) of the identified issues. In certain cases, the RCA sections were descriptive in nature, and did not identify the systemic origins of the observations. Consequently, it cannot be ensured with full confidence that all underlying causes have been addressed or that the proposed corrective measures will effectively prevent recurrence. The Commission therefore considers that the RCA methodology applied by the CAC requires further refinement and verification to ensure the sustainability and effectiveness of the corrective actions implemented.

(41) By letter dated 22 October 2025, the Commission, following a request from the CAC to be heard, informed the Armenian authority that the case of Armenia would be included on the agenda of the EU Air Safety Committee meeting scheduled for 19 and 20 November 2025, where the CAC would have the opportunity to present its case in the framework of Regulation (EC) No 2111/2005.

(42) The CAC was heard by the EU Air Safety Committee on 19 November 2025. During the hearing, the Armenian delegation presented an overview of reforms undertaken since 2020 and highlighted actions it had taken to strengthen safety oversight, including organisational adjustments, recruitment efforts and the introduction of internal procedures. The CAC reported that it had closed 31 out of 58 observations raised during the Union on-site assessment visit, and considered the remaining observations to be procedural in nature.

(43) While the Commission and the EU Air Safety Committee noted the efforts described, the information provided by the CAC did not fully support the conclusions presented. The CAPs submitted on 27 October 2025 did not demonstrate that the root causes of the identified issues had been sufficiently analysed or addressed. In addition, the Commission and the EU Air Safety Committee could not validate the closure of the 31 observations referred to by the CAC, as their closure was based on the CAC’s own interpretation rather than on evidence demonstrating effective resolution. When questioned during the hearing, the CAC acknowledged that the status of several observations might need to be reassessed once the Commission comments on the CAPs were received.

(44) The Commission and the EU Air Safety Committee also observed that the CAC tended to minimise several deficiencies identified during the Union on-site assessment visit. This included gaps in inspector qualification and authorisation, such as incomplete training and inaccurate competency mapping, as well as poor management of findings, including findings closed without corrective actions or RCAs. In addition, weaknesses showing that oversight activities are not yet functioning as a coherent system, such as the use of inappropriate checklists and uncontrolled parallel surveillance plans, were presented as minor. These issues indicate that key systemic shortcomings, particularly in Flight Operations, have not been consistently addressed.

(45) The CAC expressed its view that Armenian air carriers should be removed from Annex A to Regulation (EC) No 474/2006, and proposed that any lifting of restrictions be accompanied by time bound monitoring. However, based on all available evidence, including the Union on-site assessment, the documents provided by the CAC since the Union on-site assessment visit, and the CAC’s hearing, the Commission and the EU Air Safety Committee concluded that the corrective actions remain incomplete, and that a robust RCA is still lacking. While progress has been made, it is concluded that the CAC has not yet effectively addressed all safety deficiencies that led to the operating ban imposed by Implementing Regulation (EU) 2020/736.

(46) In accordance with the common criteria set out in the Annex to Regulation (EC) No 2111/2005, the Commission considers that at this time there are no grounds for amending the list of air carriers which are subject to an operating ban within the Union with respect to air carriers certified in Armenia.

(47) Member States should continue verifying the effective compliance of air carriers certified in Armenia with the relevant international safety standards through prioritisation of ramp inspections of those air carriers, pursuant to Regulation (EU) No 965/2012.

Air carriers from Kyrgyzstan

(48) In October 2006, air carriers certified in Kyrgyzstan were included in Annex A to Regulation (EC) No 474/2006, by Commission Regulation (EC) No 1543/2006 (11).

(49) In the context of ongoing exchanges, resulting from renewed contacts between the Commission and the State Civil Aviation Agency under the Cabinet of Ministers of the Kyrgyz Republic (‘SCAA’) since 2023, the Commission launched a technical assistance initiative, implemented by the Agency, within the framework of Regulation (EC) No 2111/2005. That initiative aimed to support SCAA efforts to enhance its oversight capacity.

(50) On 7 and 8 October 2025, as part of the Commission’s continuous monitoring activities regarding the overall safety situation in Kyrgyzstan, including the safety oversight capacity and capabilities of SCAA, a technical meeting took place involving the Commission, the Agency, Member States and SCAA.

(51) During this meeting, the SCAA presented the noteworthy progress achieved between May and October 2025 in strengthening the civil aviation system of Kyrgyzstan, particularly in relation to the legislative framework, institutional capacity, and oversight activities. The Commission took note that the new Air Code of Kyrgyzstan had been adopted by Parliament and was due to be promulgated, and that several National Aviation Rules, transposing ICAO Annexes 1, 6, 7 and 8, had been approved, with additional drafts, including the transposition of Annex 19, under consultation. Furthermore, the SCAA reported a doubling of staff in the fields of air operations, personnel licensing and airworthiness, as well as the establishment of dedicated teams for quality and safety management. A comprehensive training programme had been implemented, including ‘train-the-trainer’ activities, and working conditions and IT infrastructure had been substantially improved.

(52) The SCAA communicated that, in anticipation of the entry into force of the new regulatory framework, it had conducted a recertification exercise with several air carriers to prepare them for the new forthcoming certification requirements. Four air carriers participated in this exercise, which was carried out using the newly developed checklists and procedures. The purpose was to familiarise both the air carriers and SCAA inspectors with the new provisions, and to identify potential gaps ahead of their formal implementation, serving as a preparatory and training activity for all parties involved.

(53) The SCAA further presented its plans to implement risk-based oversight, building upon data analysis and air carrier performance indicators, as well as the establishment of a clear enforcement framework to address safety concerns and non-compliance.

(54) During the two-day technical meeting, the Commission acknowledged the progress achieved by Kyrgyzstan in strengthening aviation safety oversight during 2025. Notable improvements were observed in the development of the legislative and regulatory framework, the enhancement of institutional capacity, and the establishment of internal procedures supporting consistent implementation. These achievements reflect the strong commitment of the SCAA and its leadership to advance the safety reform agenda, and to align the national aviation system with international safety standards. The Commission commended the proactive and constructive approach demonstrated by the Director-General of the SCAA, whose strategic leadership has been instrumental in driving these reforms and sustaining progress in a demanding environment, making use of effective external expertise.

(55) Nevertheless, the Commission noted that the implementation of the new regulatory framework remains at an early stage, as the Primary and Secondary Legislation had not yet entered into force at the time of the meeting. Consequently, a full recertification of air carriers under the new rules cannot yet be considered. It was communicated to the SCAA that a Union on-site assessment visit to Kyrgyzstan could only be envisaged once the new legislation is fully applicable and the recertification of all air carriers has been completed.

(56) On 7 November 2025, the SCAA transmitted to the Commission a letter providing an update on the progress achieved since the technical meeting of 7–8 October 2025, together with the supporting evidence. The information submitted covered developments across the legal, air operations, airworthiness, personnel licensing and safety management areas. Several of the documents were submitted in final draft form and were undergoing the concluding steps of approval. The SCAA further informed the Commission that the Cabinet of Ministers of the Kyrgyz Republic had adopted Order No. 975-t on 11 November 2025, authorising the early applicability of the amended Air Code and enabling the SCAA to commence the recertification of national air carriers as from 1 December 2025.

(57) Based on the discussions held during the technical meeting and the commitments confirmed in the SCAA’s letter of 7 November 2025, the Commission considers that a Union on-site assessment visit to Kyrgyzstan could be envisaged for March 2026. The organisation of such a visit would be conditional upon the fulfilment of specific safety prerequisites, including adequate staffing levels within the SCAA, an appropriate number of air carriers proportionate to its oversight capacity, and the effective implementation of the new certification requirements under the amended Air Code. It was agreed that Kyrgyzstan’s readiness to host such a visit will be reviewed in February 2026.

(58) The Commission will continue to monitor developments closely, with particular attention to the recertification process of air carriers. While acknowledging the ongoing efforts of the SCAA to strengthen its safety oversight system, the information currently available does not yet provide sufficient verified evidence to confirm that the SCAA has effectively resolved all the safety deficiencies that led to the operating ban imposed by Regulation (EC) No 1543/2006.

(59) In accordance with the common criteria set out in the Annex to Regulation (EC) No 2111/2005, the Commission considers that at this time there are no grounds for amending the list of air carriers which are subject to an operating ban within the Union with respect to air carriers certified in Kyrgyzstan.

(60) Member States should continue verifying the effective compliance of air carriers certified in Kyrgyzstan with the relevant international safety standards through prioritisation of ramp inspections of those air carriers, pursuant to Regulation (EU) No 965/2012.

(61) Regulation (EC) No 474/2006 should therefore be amended accordingly.

(62) Articles 5 and 6 of Regulation (EC) No 2111/2005 recognise the need for decisions to be taken swiftly and, where appropriate, urgently, given the safety implications. It is therefore essential, for the protection of sensitive information and the traveling public, that any decisions in the context of updating the list of air carriers which are subject to an operating ban or restriction within the Union apply immediately after their adoption.

(63) The measures provided for in this Regulation are in accordance with the opinion of the EU Air Safety Committee,