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N Reg Rental - legal in the UK?

I know this has been done to death however not recently after 2016!

There is a lot of conflicting information on the internet and It is not easy to get hold of the CAA either! Would appreciate peoples thoughts on the below on our buddy ‘Jim’

Jim likes to fly. Jim wants to also be able to cover some of the costs of the aircraft through rental. To make things slighly more complicated Jim likes to fly IFR on his FAA privileges. Therefore Jim bought himself a high performance N reg plane. e.g. Piper Meridian on Part 91.

1. Dry hire of a N reg aircraft through UK LTD company where renters also join to become members for a one off fee.
2. Pilots will be required to hold FAA & EASA license if they wish to fly abroad.
3. Some customers may wish to fly & pay for a CPL. Through there own enquiries they find a pilot who is a FAA/EASA CPL who is paid directly.

Jim understands that he will have to pay the same rate it is hired out to others, and indeed the VAT if applicable. Jim knows that the above would be perfectly legal in the states, however is unsure about CAA/EASA with point 3. The FAA requirement is met If your customer approaches you, with his own airplane (either he rented it himself, or he owns it). In this case you may fly for hire, because you are not offering your services as a package or “holding out” as a commercial operator — air taxi or charter.

In addition the EASA license is required for…well I am entirely unsure on this one!

United Kingdom

Porchy wrote:

Jim bought himself a high performance N reg plane. e.g. Piper Meridian

A good idea but I would have thought that any owner of an aircraft like this would want a cleared deposit equal to the cost of an engine overhaul in case of a Hot Start or worse.

I understand that as an issue however it is something about risk rather than regulatory!

United Kingdom

There was some stuff going around about 15 years ago, saying that you could not rent out an N-reg. Only a dry lease was permitted. The assertion was spread by one then “famous” UK GA personality who later stopped flying for some years, though he appears to be back now. He claimed it was due to an intersection of UK and US regulations.

When I went N-reg in 2005 I was renting my plane out and I tried to check out this story. I contacted this guy and he could not support his earlier position (he just got really vague). This didn’t surprise me since he came up with other stuff which turned out to be bollox.

I even phoned up an official at the Dept for Transport who told me there is no problem renting, but he warned me about being in the plane when the renter is flying it. I didn’t follow up the significance of this or what legal principle supported it, but it appears to be this i.e. cost sharing is indeed illegal in an N-reg (or any non G-reg) in UK airspace. Of course just because the owner is a passenger doesn’t mean he is cost sharing, but somebody could claim the flight was cost-shared after an accident, if it produces a bigger payout for the other person

The pilot(s) will also need EASA papers (in addition to the FAA ones) – a complex picture and the thread is here.

The thing about renting it out at the same rate as renting to yourself is a different issue. Search EuroGA for
benefit in kind
and you will get plenty of reading It isn’t a complete defence against BIK though; HMRC just like hitting anybody who is successful because they know a successful businessman will write a cheque to get them off his back no matter how much foul taste it leaves in his mouth; getting justice is something which interests only the poor or the very rich. You need a classy accountant do deal with this aspect; not the normal street-corner type.

Paying a CPL (CPL/IR to be practical, on a PA46T) to fly the owner of the plane around is how the bizjet scene has run since for ever. What I don’t know is whether this is still legal if the owner is not on board, but it should be because a lot of bizjets are leased. What you cannot do is offer someone a package that includes a plane and a pilot, or any situation where somebody is paying somebody for getting flown. That would be an illegal charter.

You could also try a search on “dry lease” (with the double quotes).

I wonder if @bookworm knows about anything recent in this area.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I even phoned up an official at the Dept for Transport who told me there is no problem renting, but he warned me about being in the plane when the renter is flying it. I didn’t follow up the significance of this or what legal principle supported it, but it appears to be this i.e. cost sharing is indeed illegal in an N-reg (or any non G-reg) in UK airspace.
That can’t be true for “any non G-reg”. If some part of the ANO actually says so, it is in conflict with the EASA Air Ops regs and thus void. (At least for another year or so. :-) )

ESKC (Uppsala/Sundbro), Sweden

I think the latest ANO is here local copy and sure enough you are right and the wording was changed recently to “EEA”:

Interesting that M-reg are included. They probably got included because the IOM CAA no longer accepts Part 91 maintenance and requires EASA Part M so that is the quid pro quo here

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Interesting that M-reg are included. They probably got included because the IOM CAA no longer accepts Part 91 maintenance and requires EASA Part M so that is the quid pro quo here

This is from IOMAR Publication 9:

3. Validations (Engineers / Mechanics / Technicians) The IOMAR-ANO Identifies who may issue a certificate of release to service, this includes the holder of an AMEL rendered valid under the ANO.

The department may, subject to any conditions as it thinks fit, issue a certificate of validation of: an aircraft maintenance engineers licence granted in accordance with the laws and procedures of a contracting state.

The AMEL validation process by the IOMAR, falls in to 2 methods of licence status.  Type Rated (eg, EASA / CASA Part 66)  Non Type Rated ( eg FAA A&P / TCCA “M”) The following tables identify the requirements to be satisfied and relevant documents required to reach a validation issue.

Darley Moor, Gamston (UK)

My post was based on a meeting with the Director of Aviation at the IOM, a few years ago.

I would expect they allow an FAA A&P to actually perform the work i.e. no need for an EASA66 which is the EASA equivalent of an A&P (and there are cross-credits).

What you don’t get, apparently, on the M-reg, is Part 91 maintenance “on condition”.

Administrator
Shoreham EGKA, United Kingdom

As the aircraft on the Isle of Man register are almost exclusively jets above 12,500lbs I don’t think it makes any practical difference.
Every jet operator I know (and that’s quite a few) maintain in accordance with the Manufacturers maintenance schedule.

I suppose that somebody might conceivably want to make up their own maintenance schedule, or just not have one, but surely that only applies to aircraft of negligible value, because to do so would destroy the maintenance history. I don’t think that the Isle of Man are missing out if they choose not to have such aircraft on their register.

Darley Moor, Gamston (UK)

Thankyou all, very informative!

United Kingdom
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