Pakistan
Insights
Contributor
Question 1. Is there an Aircraft Register in Pakistan?
Yes, pursuant to Section 50 of the Pakistan Civil Aviation Act, 2023 (the “PCAA Act”) read with Rule 6 of the Civil Aviation Rules, 1994 (the “CAR”), the Pakistan Civil Aviation Authority (the “CAA”) maintains an aircraft register called the Civil Aircraft Register of Pakistan (the “Pakistan Aircraft Register”).
2. What are the requirements in respect of the registration of aircraft in Pakistan?
Pursuant to Section 47 of the PCAA Act, no aircraft shall fly, from to, within, or over Pakistan unless it is registered in Pakistan, a contracting State of the International Civil Aviation Organization established under the Convention on International Civil Aviation signed at Chicago on 07 December, 1994 (the “ICAO”) or any other State that is a party to an agreement with Pakistan providing for each other's acceptance of registration of aircraft. Further, any aircraft which is not currently registered and entered in an aircraft register of any other State shall be eligible for registration in Pakistan, if: (a) it is owned by a citizen of Pakistan; (b) it is a leased aircraft exclusively operated by an operator having its principal place of business in Pakistan and who has a current and appropriate Air Operator Certificate issued by the Director General; (c) it is owned by a body corporate or a body incorporated under the laws of Pakistan, having its principal place of business in Pakistan with majority of voting rights and shareholdings held by citizen of Pakistan; or (d) it is an aircraft owned by the Federal Government, the government of any province of Pakistan or any office, authority, company or other body which is owned or controlled by any of such governments. An application for registration of an aircraft in Pakistan shall be made to the Director General in such form and in such manner as may be prescribed by the rules. No such application shall be considered by the Director General unless it is complete and accompanied by receipt of payment of such fee as may be prescribed by the regulations. No aircraft shall be registered, or remain registered in Pakistan if it is registered in any other State.
As per para 5.1.3 of the ANO-016-FSXX-3.0 dated 15 March 2018, all aircraft intended to be operated by a Pakistani operator under dry lease agreement must be registered in Pakistan and entered in the Operations Specifications of the local operator, and must have valid documentation.
Pursuant to Rule 8 of CAR, an application for the inclusion of an aircraft in the Pakistan Aircraft Register and for the issue of certificate of registration (the “COR”) shall contain the following information:
(a) the name of the manufacturer;
(b) the manufacturer's designation of the aircraft;
(c) the serial number of the aircraft;
(d) the name and addresses of all persons or organizations who have a legal interest as owners of the aircraft;
(e) if the aircraft is the subject of a hire purchase or leasing agreement, the name and address of the person or persons or organization purchasing or leasing the aircraft; and
(f) a declaration as to the truth of the statement set out in the application.
Additionally, pursuant to paragraph D3 of the Air Navigation Order, ANO-023-AWRG-2.0, dated 02 December 2023, an application for registration of an aircraft may be made by a person or organization holding an interest as owner in the said aircraft, but where two or more persons or organizations, hold joint interest as owner, hire purchaser or lessors, they shall have to clearly nominate one of them as the person or organization to whom Certificate of Registration (“COR”) may be issued. Further, an application for registration of an aircraft may be made, on behalf of the owner or the organization, by an authorized designee authorized by virtue of appropriate Power of Attorney. Moreover, an application for registration of aircraft shall be submitted to Director Airworthiness on prescribed Form CAAF-128-AWRG-4.0, as amended from time to time, duly filled with required information and signed by the owner or an authorized designee. Every applicant for registration of an aircraft shall furnish the Director Airworthiness with such particulars relating to the aircraft and the ownership thereof as he may require in connection with the application and with such evidence as he may require in support thereof, and shall pay the appropriate fee as prescribed from time to time in AWNOT-003-AWRG-9.0 dated 20 February 2026. The application for registration of an aircraft shall be supported by the following documents, where applicable:
(a) Proof of ownership of existing owner of the aircraft;
(b) Type Certificate (TC) issued by FAA/ EASA/ CAA/ NAA, where applicable (required only for first type of aircraft to be registered in Pakistan);
(c) Type Acceptance Certificate (TAC) issued by CAA (required only for first type of aircraft to be registered in Pakistan);
(d) Proof of deregistration/no registration from previous state of registration (where applicable);
(e) Aircraft lease agreement (where applicable);
(f) Export Certificate of Airworthiness (where applicable);
(g) Valid Air Operator Certificate(s) held by prospective aircraft operator (where applicable);
(h) No-Objection Certificate for import of aircraft in Pakistan duly issued by CAA;
(i) Aircraft customs clearance documents (required, when the aircraft is in Pakistan);
(j) Documentary evidence of existence of prospective legal entity (owner and/or operator);
(k) Complete trail of relevant documents related to ownership and/or lease agreement(s) of the aircraft;
(l) Power of attorney by the owner(s) or the organization in favor of the authorized designee. In case any person is further delegating his/her power to any other person under delegated authority, documents are also required to determine the complete trail to ascertain the delegation of powers. Where the owner is an organization, proof of such authorization in shape of Board of Directors’ Resolution or any other legal document is required;
(m) An affidavit as to the truth of the statements set out in the application; and
(n) Proof of payment of required registration fee as prescribed from time to time in AWNOT-003-AWRG-9.0 dated 20 February 2026.
The supporting documents mentioned hereinabove is not exhaustive and the Director Airworthiness may require such other evidences / documents relating to the aircraft and the ownership thereof as he may deem appropriate. Where applicable and practicable, original documents shall be presented for verification and notarized copies of the documents mentioned hereinabove shall be submitted to the Director Airworthiness for registration of aircraft. On receipt of an application for registration of an aircraft, the Director Airworthiness shall, when he is satisfied of the accuracy of the information given in the application and after satisfactory induction/inspection by the CAA inspection team for the purpose of registration, enter the relevant details in the Pakistan Aircraft Register and issue a COR, after getting approval of Director General of CAA, to the owner of the aircraft, or to the person nominated in the application as the person to whom such a certificate may be issued. COR shall be issued on latest issue of CAAF-026-AWRG, which shall contain all information as prescribed in ICAO Annex-7.
An applicant applying for re-registration of the aircraft previously de-registered from Pakistan Aircraft Register shall comply with applicable requirements mentioned hereinabove. However, where aircraft is not registered in any other contracting state after de-registration, may be re-registered on Pakistan Aircraft Register with the approval of Director General of CAA or Director Airworthiness, as the case may be, without fulfilling the requirements mentioned at paragraph D3.3 of the Air Navigation Order, ANO-023-AWRG-2.0, dated 02 December 2023.
Please note that, in practice, where original documents are being provided, copies of such documents (including any powers of attorney) are also required to be submitted to the CAA. The CAA will retain the copies and return the originals. If originals are not being provided, notarized and apostilled copies are required to be provided. Documents that are required to be notarized and apostilled must be attested by the competent authority at the place of execution of such documents.
3. What are the requirements for the change of ownership registration.
The latest prescribed form CAAF-128-AWRG-4.0 (Application for Issue of Certificate of Registration / Cancellation of Registration / Change of Registration Details) stipulates that the originals along with apostilled/notarized copies of the following documents are required for the purposes of effecting the change of ownership registration:
i. Proof of ownership along with relevant power of attorney/ authority letter if the application is signed by person other than owner of aircraft;
ii. Section-I/IV of original COR duly filled;
iii. Lease agreement between owner/lessor/lessee and operator along with AOC copy of new operator, if relevant;
iv. Fee submission as per the latest issue of Airworthiness Notice, AWNOT-003-9.0 dated 20 February 2026 (Airworthiness Service Charges).
The above-mentioned documents can be pre-positioned with the operator (since the COR is kept with the operator) for filing immediately upon closing of the transaction. If the operator is reluctant, such documents may be pre-positioned with the local counsel for necessary action post novation.
4. What fees are payable on the registration of an aircraft?
Pursuant to Airworthiness Notice AWNOT-003-AWRG-8.0 dated 04 April 2022, the fee payable in relation to the COR are as follows:
(a) Initial reservation of registration mark (60 days) - PKR 9,300
(b) Each subsequent extension(s) in reservation (60 days) - PKR 15,500
(c) Issue/ re-issue of COR for Ultralight/LSA/ Airship/ Balloons/Amateur built aircraft - PKR 6,975
(d) Issue/re-issue of COR for aircraft up to 5,700 kg - PKR 13,175
(e) Issue/re-issue of COR for aircraft above 5,700 kg - PKR 31,000
(f) Out of series/special registration mark of applicant’s choice – PKR 775,000
5. It is unlawful for an airline to operate an aircraft which is not currently registered with a national aviation authority? What civil and/or criminal penalties would be imposed? Would such penalties give rise to a lien or risk of seizure or detention of the aircraft? Would loss of registration of the aircraft result in loss of registration of a mortgage recorded against the aircraft?
Yes. Pursuant to Section 47 of the PCAA Act, no aircraft shall fly, from to, within, or over Pakistan unless it is registered in Pakistan, a contracting State of the International Civil Aviation Organisation or any other State this is party to an agreement with Pakistan providing for each other's acceptance of registration of aircraft.
Further, Rule 7 of the CAR also states that aircraft not registered in the Pakistan Aircraft Register or not registered in a contracting state (which is defined to include a country which is a party to the Convention on International Civil Aviation concluded at Chicago on 7 December 1944) shall not be allowed to fly.
Operating an aircraft which is not currently registered with the CAA or in a contracting state would be considered as a failure to comply with rule 7 of the CAR and hence pursuant to Rule 333(2) of CAR the owner (i.e., the lessor), the operator, the hirer (i.e., the lessee) and the pilot-in-command and any other pilot, would be guilty of an offence, as per rule.
Pursuant to the Section 123 of the PCAA Act, where any rule or regulation provides that a contravention thereof shall be punishable, a person contravening that rule or regulation shall be punished with simple imprisonment for a term which may extend to three months or fine which may extend to one hundred thousand rupees, or with both.
According to Rule 333(5) of the CAR, an offence, not being an offence for which a penalty is prescribed otherwise by this rule, shall be punishable with fine not exceeding one hundred thousand rupees or with imprisonment for a term not exceeding six months, or both.
Further, pursuant to Section 115 of the PCAA Act, whoever does any act in relation to the operations, maintenance, or service of an aircraft, airport, or aeronautical product, or provides any aviation service for which an aviation document (i.e. a licence, permit, certificate, authorization, approval or any other document issued under the PCAA Act to or in respect of any person, aircraft, airport, air service, aviation service or aeronautical product) is required under the PCAA Act, without holding a valid aviation document, shall be punished with simple imprisonment for a term which may extend to one month or with fine which may extend to five hundred thousand rupees, or with both.
The loss of registration of the aircraft would not in and of itself result in loss of registration of a mortgage recorded against the aircraft at the international registry if the ownership title to the aircraft has, otherwise been, duly vested in favour of the owner of the aircraft.
Submission date: 2 October 2026
Ashraf Law Chambers is a leading full service law firm in Pakistan. The firm has extensive expertise in aircraft leasing, financing, assignments of insurances and securitisations. The team has expertise in engine leasing, escrow arrangements and state of registration legal opinions.
Sheheryar Ashraf heads the aviation practice and has vast experience of advising multiple lessors, security trustees, export-import banks and magic circle law firms. He also has contributed to multiple legal directories and attended meetings with the Aviation Working Group.
Sheheryar Ashraf
Registration and change in registration of Aircraft
