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Aviation Q&A – 20 things to consider for aviation deals in the UAE 6 August 2026

The UAE has established itself as one of the world’s leading aviation hubs, underpinned by a sophisticated regulatory framework, modern aviation infrastructure and a legal regime that is increasingly aligned with international financing and leasing practices. As a Contracting State to the Cape Town Convention and home to globally recognised carriers and airports, the UAE offers a creditor-friendly environment for aircraft lessors, financiers and operators. Whilst certain local law nuances remain relevant, particularly in relation to enforcement and repossession, the combination of GCAA oversight, established registration procedures and recent legislative reforms has strengthened the UAE’s position as a key jurisdiction for aviation investment and cross-border aircraft transactions. This article provides an overview of the principal legal, regulatory and practical considerations affecting aircraft leasing, financing and asset management in the UAE. 

Regulatory and legal framework

 1. Which authority regulates aircraft operation and registration in the UAE?

General Civil Aviation Authority (the “GCAA”) is responsible for aircraft operation and registration in the UAE.

"At a conceptual level, UAE law does not specifically contemplate aircraft mortgages. UAE law does, however, recognise security interests that are similar to a common law mortgage and there is a well-established practice of lodging aircraft mortgages with the GCAA."

2. Are aircraft mortgages, leases and security interests recognised and enforceable? What local formalities apply?

At a conceptual level, UAE law does not specifically contemplate aircraft mortgages. UAE law does, however, recognise security interests that are similar to a common law mortgage and there is a well-established practice of lodging aircraft mortgages with the GCAA. Such mortgages are typically governed by New York or English law.

The prevailing practice is not to notarise (nor to translate into Arabic) aircraft mortgages at the time of their execution. It is, however, advisable that an aircraft mortgage be lodged (but not formally filed) with the GCAA in accordance with the process set out in the UAE Civil Aviation Regulations (“CAR”). In practical terms, this typically includes the submission to the GCAA of an English language certified true copy of the relevant mortgage instrument, together with evidence of the relevant signatories’ respective managerial positions and authorisations.

Aircraft lease agreements are recognised under UAE law and Part V of the CAR requires submission of certified copies thereof when registering (or amending the registration particulars) of an aircraft.

Aircraft lease agreements do not need to be notarised or filed with any UAE registry or authority. Similarly, the prevailing practice is not to translate aircraft lease agreements into Arabic at the time of their execution.

3. Is the jurisdiction a Contracting State (under the Cape Town Convention)? If so, how is the Cape Town Convention implemented in practice?

Yes, the UAE is a Contracting State under the Cape Town Convention (and Protocol), with both becoming effective in the UAE on 1 August 2008. The UAE has made declarations under Articles 39(1)(a) – (b), 40, 52, 53 and 54(2) of the Cape Town Convention.

As such, aircraft mortgages, leases and associated security assignments will, provided they are registered at the International Registry, constitute enforceable international interests or assignments of international interests (as applicable).

The UAE currently scores 88 (Very High) on the Aviation Working Group’s Cape Town Convention Compliance Index.

In August 2024, the UAE amended Federal Civil Aviation Law No. 20 of 1991 (the “Civil Aviation Law”) to clarify that the Cape Town Convention supersedes any conflicting provision of the Civil Aviation Law. As a result, international financiers and lessors can take comfort as to enforceability of the Cape Town Convention and the availability of its remedies in the UAE (to the extent of the relevant declarations). In addition, the UAE now meets the criteria prescribed in the OECD Aircraft Sector Understanding for eligibility for the Cape Town discount, with UAE operators becoming eligible for a reduction of up to 10% on upfront fees/per annum spreads charged by export credit agencies.

4. What local licencing or approvals are required for foreign lessors or financiers to enter aviation transactions?

It is not necessary that, merely by reason of financing or leasing of a UAE-registered aircraft, the relevant financier or lessor be licenced or otherwise qualified to conduct business in the UAE.

It should be noted that aircraft, airframes, helicopters and aircraft engines of any type that are subject to registration in special registers, pursuant to the legislation in force in the State and international treaties and conventions to which the UAE accedes (i.e. the Cape Town Convention) are excluded from the purview of the UAE’s Financial Leasing Law.

5. Are there any foreign ownership or control restrictions that impact airline counterparties?

No. There are no foreign ownership or control restrictions in place that impact airline counterparties.

Registration, deregistration and repossession

6. What is the process and timeline for aircraft registration and deregistration?

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"For applications involving corporate owners, operators and mortgagees, this involves submitting a completed application form to the GCAA via its online portal and as a hard copy, along with relevant supporting materials."

Aircraft registration follows the process prescribed by Part V of the CAR. For applications involving corporate owners, operators and mortgagees, this involves submitting a completed application form to the GCAA via its online portal and as a hard copy, along with relevant supporting materials. This includes:

  • notarised power(s) of attorney evidencing the authority of the interested party(ies) representatives/signatories to represent them before the GCAA;
  • certified copies of the aircraft owner’s constitutional documents and corporate registry extracts;
  • copies of registers of directors (or analogous documents evidencing managerial titles);
  • a certified copy of the aircraft bill of sale, evidencing the owner’s title to the aircraft;
  • a certified copy of the aircraft mortgage (if any);
  • a certified copy of the aircraft lease, together with evidence of due authority of the relevant signatories;
  • the IDERA;
  • a copy of the aircraft non-registration/deregistration certificate (other than in the case of a new aircraft);
  • certified and notarised copies of “no objection” letters from the lessor and the mortgagee consenting to the registration of the aircraft in the UAE;
  • certified copy of the insurance certificate for the aircraft; and
  • a CD or flash drive containing the above documents.

The registration application must also be accompanied by payment of the associated registration fee to the GCAA.

Registration of a commercial aircraft with the GCAA generally takes between two and six weeks, though this general timeframe may vary depending on the individual operator’s identity and the steps (if any) taken by it to preposition such registration in advance of delivery.

For deregistration of an aircraft, the applicant must submit the relevant application form to the GCAA, together with the following:

  • key details of the aircraft (make, model, registration mark, etc.);
  • reason for the deregistration registration request;
  • if applicable, details of the export registry;
  • evidence that the registered owner has consented to the deregistration request (together with evidence of corporate authority to provide such consent on behalf of the relevant entity);
  • a notarised no objection certificate from the mortgagee (together with evidence of corporate authority to issue such certificate);
  • where the application is made by a person other than the operator, evidence of the operator’s acknowledgment of the deregistration (or cancellation or termination of the lease agreement);
  • surrender of originals of the certificate of registration and other certificates issued by the GCAA in relation to the aircraft (e.g. noise certificate, radio licence, certificate of airworthiness, etc.);
  • evidence of removal of registration marks from the aircraft;
  • evidence of cancellation of Mode S and ELT codes; and
  • a deregistration consent letter from the entity entitled under the IDERA or an IDERA revocation letter issued by the person entitled under the IDERA.

The deregistration request must also be accompanied by payment of the associate deregistration fee to the GCAA, together with settlement of any outstanding air navigation, airport and similar charges.

Deregistration of a commercial aircraft with the GCAA generally takes between one and two weeks, though this general timeframe may vary depending on the individual operator’s identity and any steps taken to preposition such deregistration in advance of redelivery under the lease.

7. Is an IDERA recognised and effective in practice?

The GCAA has previously indicated that it would recognise the rights of an “authorised party” identified in an IDERA and would give effect to the rights and remedies granted pursuant to an IDERA.

The GCAA has also established a procedure for the enforcement of IDERAs pursuant to Part V of the CAR. This procedure does not expressly contemplate the leave of UAE courts.

However, the general position under UAE law is that provisions in documents entitling a party to take possession, sell or enforce against any asset will not be enforceable without a prior court order permitting the same. In addition, the UAE has declared under Article 54(2) of the Cape Town Convention that “any remedies available to a creditor under the Cape Town Convention…may be exercised only with the leave of the court”.

Moreover, self-help repossession remedies are generally not recognised in the UAE.

On balance, therefore, in a non-consensual repossession scenario the GCAA would likely require sight of an appropriate court order before permitting or facilitating the deregistration and export of an aircraft from the UAE.

8. Are self-help remedies permitted, or is court intervention typically required?

Self-help repossession remedies are generally not recognised in the UAE, meaning court intervention would be required.

9. In the event of a default, how easy is it for a lessor or financier to repossess an aircraft?

The process of repossessing an aircraft from a defaulting debtor or lessee in the UAE is likely to take between two and six months.

That said, in a non-consensual repossession scenario, judicially directed remedies would be available to a lessor or mortgagee. This includes interim relief, whereby the relevant creditor may apply for a precautionary attachment either before or after commencing substantive proceedings. If an application for a precautionary attachment is made prior to commencement of the main/substantive proceedings, the UAE courts will require the creditor to commence proceedings for recovery of the underlying debt within eight days of the pre-judgment attachment being enforced over the aircraft, failing which the attachment may be vacated and held to be null and void. To be successful, there are several requirements which must be fulfilled including an applicant demonstrating that there is a real risk of the aircraft being lost (or moved out of jurisdiction) or any judgment rendered in substantive proceedings being otherwise frustrated.

As regards substantive repossession proceedings, the onshore UAE courts (i.e. civil and commercial courts of individual emirates and the federal courts of the UAE) have wide discretion and the outcome of proceedings can be difficult to predict. The general consensus among practitioners remains that the Cape Town Convention and the Protocol should substantially simplify the procedure for repossession and deregistering aircraft in the UAE.

Contracting and Local Law Requirements

10. Are local law governed lease or security documents required, or is English or New York law sufficient?

"UAE law recognises the principle of freedom of contract, which theoretically also extends to choice of law provisions."

UAE law recognises the principle of freedom of contract, which theoretically also extends to choice of law provisions. The UAE courts tend to respect foreign arbitration provisions, given the UAE is a signatory to the New York Convention. However, in an action brought before the UAE courts against a person resident or incorporated in the UAE, there is a possibility that the UAE courts would apply UAE law when rendering judgment.

Notwithstanding this, the practice of counterparties entering into English/New York law governed documentation is predominant and very well established.

Conversely, it would be unusual for counterparties to enter into local law governed transaction and/or security documentation (other than in respect of assets located in the UAE – for example, bank accounts). This is, in part, due to the general expectation that international interests created thereby would still be capable of enforcement in the UAE.

11. Are notarisation, legalisation or Arabic translations required for transaction documents?

The CAR prescribes what supporting documents must be provided to the GCAA when registering an aircraft in the UAE (or changing the particulars of an existing registration). Some of those supporting documents, such as powers of attorney and no-objection/consent letters would need to be notarised. Legalisation may also be required if, for example, if notarisation takes place outside of the UAE.

As to translation – all documents which become the subject of litigation in the UAE courts must either be in the Arabic language or translated into Arabic by a court-approved licenced translator. Market practice is not to translate transaction and security documents at the time of closing, as such documents can be translated at a later stage.

12. What local taxes, fees or duties apply to aircraft leases, mortgages, novations or assignments?

No local taxes or duties are applicable to leases, mortgages, novations or assignments.

Fees are payable to the GCAA for:

  • the registration or deregistration of the aircraft;
  • the lodging of an aircraft mortgage; and
  • the issuance of AEP codes for registrations at the International Registry (with one distinct AEP code being required for each aircraft object i.e. the airframe and each engine).

Relative to the value of an aircraft, these fees are generally considered insubstantial.

As noted, an enforcement scenario may involve other disbursements, such as notarisation and translation fees and any applicable court fees.

Airline financial and commercial considerations

13. What financial disclosure requirements apply to UAE airlines and how transparent is financial information?

Major UAE carriers primarily apply IFRS for the preparation of their financial statements. The extent of their publication/disclosure will vary from airline to airline. This will depend on whether a given airline is publicly listed (in which case financial disclosures will be more extensive to comply with applicable stock exchange rules) or a non-listed entity (in which case financial statements may or may not be publicised on its website, depending on its individual financial disclosure policy).

Lessors may seek to impose financial information covenants in lease agreements with UAE operators, but their exact substance will be a matter for negotiation.

14. What is the typical credit profile of operators in the region?

The UAE has a mix of government-related carriers and private operators. A significant number of those are considered tier 1 or otherwise strong credits.

15. Are there any subsidies, strategic state support or government-backed initiatives that influence risk assessment?

Certain UAE airlines benefit from state ownership, which may be seen as complementing their already strong credit standing.

UAE operators benefit from their government’s extensive investment in infrastructure, which offers a competitive advantage (particularly vis-à-vis Western carriers).

Operational and practical considerations

16. What are the key operational hubs in the UAE and how do they influence aircraft utilisation or maintenance planning?

Dubai International Airport is the primary airport of Dubai and is the world’s busiest by passenger traffic.

Dubai World Central/Al Maktoum International is Dubai’s second airport and is planned to become Dubai’s main aviation hub. Its current expansion plans envisage a capacity of 160 million to 260 million passengers per year.

Zayed International Airport is the primary airport of Abu Dhabi, with an annual passenger capacity exceeding 49 million.

"In line with international practice, it is typical for leases with UAE operators to prohibit operation in airspace/jurisdictions not covered by insurances or in a manner that would result in the lessor or the lessee violating applicable sanctions."

17. Are there restrictions on where aircraft may be based or operated due to geopolitical considerations?

There are no restrictions that are specific or unique to the UAE.

In line with international practice, it is typical for leases with UAE operators to prohibit operation in airspace/jurisdictions not covered by insurances or in a manner that would result in the lessor or the lessee violating applicable sanctions.

18. How are aircraft maintenance obligations structured and are there approved MRO providers in the jurisdiction?

Aircraft maintenance obligations in lease agreements may consider regional specifics, such as operation of engines in harsh environments. Likewise, maintenance reserve rate pricing may consider harsh environment operation.

As regards MRO providers, the UAE has a substantial MRO sector, with key providers including Etihad Engineering, Emirates Engineering, AMMROC, Sanad Aerotech, ExecuJet MRO Services, Jet Aviation and Abu Dhabi Aviation.

The UAE MRO sector caters to an extensive variety of fixed wing and rotary wing models.

Enforcement, courts and dispute resolution

19. How reliable and efficient are the courts for aviation-related disputes and is arbitration common?

There are relatively few instances of aviation-related disputes in the UAE. This, coupled with the courts’ wide discretion and the absence of a doctrine of binding precedent, means that it may be difficult to determine with certainty the outcome of an aviation dispute, particularly if it happens to touch on highly specialist issues and how long the associated court process is likely to take. That said, “offshore” specialist courts such as the DIFC courts and the ADGM courts are particularly well regarded for complex disputes and, in certain circumstances, it may be possible to enforce a DIFC court or ADGM court judgment in the “onshore” UAE courts.

Aviation-related arbitral disputes are uncommon, with it being the prevailing practice to nominate New York or English courts as the forum for disputes relating to aircraft financing and/or leasing transactions.

20. Are judgments or arbitral awards from foreign jurisdictions enforceable without excessive delay or local challenges?

A judgment from the courts of a foreign jurisdiction may be recognised and enforced by the UAE courts if the following conditions are satisfied:

"The consensus among practitioners is that the UAE courts would apply the above conditions restrictively, especially in the absence of a treaty between the UAE and the relevant foreign jurisdiction for the reciprocal recognition and enforcement of judgments."

  • there is reciprocity of enforcement between the UAE and the country in which a non-UAE judgment has been issued;
  • the UAE courts do not have exclusive jurisdiction to determine the dispute in question and the relevant foreign court has jurisdiction over the relevant dispute;
  • the foreign court’s judgment has been issued and ratified by a competent court in the foreign jurisdiction;
  • the parties to the dispute forming the subject matter of the foreign judgment were properly summoned to appear and were duly represented before the relevant foreign court;
  • the foreign court’s judgment is final and conclusive; and
  • the foreign court’s judgment does not conflict with any judgment issued by a court in the UAE and otherwise does not breach public policy, order, or morals of Sharia.

The consensus among practitioners is that the UAE courts would apply the above conditions restrictively, especially in the absence of a treaty between the UAE and the relevant foreign jurisdiction for the reciprocal recognition and enforcement of judgments. As such, enforcement of a foreign judgment is likely to prove difficult (though not impossible in the right circumstances).

An arbitral award may be ratified and enforced by the UAE courts, subject to the UN Convention on the Recognition and Enforcement of Arbitral Awards of 1958 and UAE law.

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