Regulatory & Jurisdiction Watch · 2026
This quarter's material, verifiable changes for aircraft owners were concentrated in two places: the Isle of Man is modernising its aircraft-mortgage law with a new Order that takes effect on 1 October 2026, and EASA's information-security rules (Part-IS) have reached full applicability across operators and continuing-airworthiness organisations. We also looked for a change to EU import VAT and temporary admission and found none confirmed this quarter. As always, we report only what we can tie to an official source, and we read each item from the buyer's side.
The Isle of Man is replacing its decades-old aircraft-mortgage framework with a new Civil Aviation (Mortgaging of Aircraft) Order 2026, which takes effect on 1 October 2026. The Order modernises how a lender registers and enforces a legal claim (mortgage) against an aircraft on the M-register, replacing the framework that had been in place since 1972.
According to the Isle of Man government's own consultation and industry summaries, the new Order brings tighter procedural timelines, enhanced privacy protections and greater administrative flexibility, while preserving the core protections that lenders rely on. The Isle of Man Aircraft Registry (IOMAR) is expected to publish a companion Registry Publication setting out the detailed forms, requirements and guidance.
For a buyer or financier, the Isle of Man has long been chosen partly for its reputation in aircraft finance; a modernised mortgage regime is directly relevant to that reputation. If you are financing an aircraft on the M-register, this is the quarter's change to put in front of your financing counsel. See our Isle of Man (M) profile for where the register sits among the alternatives.
The practical effect is on how security over the aircraft is created, recorded and enforced — the mechanics that determine a lender's position if the borrower defaults. A clearer, faster and more private mortgage process reduces friction in asset-backed financing, which is part of why owners and lenders use a specialist register in the first place.
The Order does not change the separate international framework: the Cape Town Convention and its International Registry continue to govern international interests, and the two operate alongside each other. A financed transaction on the M-register still needs both the domestic mortgage and, where applicable, the Cape Town registration to be handled correctly. How those pieces fit into the owning structure is the subject of our guide to aircraft ownership structuring.
Our buyer-side reading is simple: the change is favourable for financed aircraft, but the exact forms and timelines will be in the IOMAR Registry Publication, and the final enacted text should be confirmed before you rely on any specific detail. Treat the 1 October 2026 date as the point from which the new mechanics apply, and confirm the specifics with Manx counsel for your transaction.
Part-IS is the EASA framework that requires aviation organisations to manage information-security risks that could affect aviation safety, and it is now fully applicable. It is built on two regulations: Delegated Regulation (EU) 2022/1645, applicable from 16 October 2025, and Implementing Regulation (EU) 2023/203, applicable from 22 February 2026.
The Implementing Regulation covers the wider aviation population — including maintenance organisations, continuing-airworthiness management organisations (CAMO), and both commercial and non-commercial air operators. That is the part owners should note: Part-IS is not only a concern for airlines. An owner operating a complex aircraft non-commercially, and the CAMO that manages its airworthiness, sit within the population the rules address.
For most private owners the obligation is discharged through their operator or CAMO rather than personally, but the question worth asking this quarter is simple: is the organisation that manages my aircraft's airworthiness and operation compliant with Part-IS? EASA has published FAQs and continues to run implementation workshops, and the detailed entity scope should be confirmed against the EASA Easy Access Rules for Information Security.
We found no confirmed change to the EU rules on aircraft import VAT or temporary admission (TA) this quarter — and we flag the absence deliberately, because assuming a change that did not happen is as costly as missing one that did. The framework that governed importation and TA before the quarter still governs it.
The recurring reality is unchanged: full importation into free circulation triggers import VAT, while temporary admission can relieve it for aircraft that are owned, registered, based and used outside the EU, within the conditions and time limits set by the Union Customs Code and applied by national customs authorities. Those conditions are strict and are actively enforced; this is an area where the rules did not move but the enforcement attention has not relaxed.
Because rates, time limits and eligibility turn on the member state and the facts of the operation, we do not quote figures here. If importation or TA is part of your plan, confirm the current position with national customs and an aviation tax adviser, and see how it fits the wider picture in owning an aircraft in 2026.
Two developments are worth keeping in view rather than acting on yet. First, Gibraltar has moved to establish its own civil aviation authority and a new VP-G register; a new European-adjacent register changes the shortlist of flags over time, though it is early and unproven. We are watching how it positions itself before forming a view.
Second, on the Isle of Man, the companion Registry Publication to the new mortgage Order — the document that will carry the operative forms and procedural detail — is the piece to watch as the 1 October 2026 effective date passes. Until the final text and the RP are confirmed, the specifics should be treated as provisional.
We do not report rumours or pre-decisional proposals as if they were rules. Everything in this watch is either in force, dated, or clearly labelled as something we are monitoring — and nothing here replaces confirmation with the relevant authority for your specific case.
If you are financing an aircraft on the Isle of Man register, put the new Civil Aviation (Mortgaging of Aircraft) Order 2026 in front of your financing counsel now, and confirm the IOMAR Registry Publication detail before completion. The direction is favourable, but the mechanics are what matter at signing.
If your aircraft is complex and operated non-commercially, ask your operator and CAMO to confirm their Part-IS position; it is their obligation more than yours, but it is your aircraft's airworthiness management that must remain compliant. And if importation or temporary admission is in your plan, do not assume anything changed — confirm the current VAT position independently.
The common thread is the one that runs through everything we publish: the flag and the framework set the rules, but your exposure depends on how your specific structure, financing and operation are built on top of them. That is the analysis we run on the buyer's side, before a transaction closes rather than after.
Common questions
The Civil Aviation (Mortgaging of Aircraft) Order 2026 takes effect on 1 October 2026, replacing the framework in place since 1972. The Isle of Man Aircraft Registry is expected to publish a companion Registry Publication with the detailed forms and requirements; confirm the final text and guidance with IOMAR and Manx counsel before relying on specifics.
Part-IS obligations fall on organisations — operators and continuing-airworthiness management organisations (CAMO), among others — rather than on individual owners directly. Implementing Regulation (EU) 2023/203, applicable from 22 February 2026, covers both commercial and non-commercial air operators, so the CAMO and operator managing a complex privately operated aircraft sit within its scope. Confirm your organisation's status against the EASA rules.
We found no confirmed change to the EU import-VAT or temporary-admission framework this quarter. The existing rules under the Union Customs Code continue to apply, and enforcement remains active. Rates, time limits and eligibility vary by member state and by the facts, so confirm the current position with national customs and an aviation tax adviser.
Part-IS is an information-security framework aimed at risks that could affect aviation safety. It is distinct from the continuing-airworthiness rules (Part-M, Part-CAMO, Part-145) but applies to many of the same organisations, including CAMOs and maintenance organisations, which must manage information-security risks alongside their airworthiness responsibilities.
We cite official and primary sources wherever possible — EASA publications and EUR-Lex for the regulations, and the Isle of Man government and Aircraft Registry for the Manx mortgage Order — alongside recognised industry reporting. Where a detail could not be confirmed against a primary source, we say so. Nothing here is legal, tax or financial advice.
Primary references
Links to official sources. Specifics vary and change over time; confirm any point with the relevant authority before relying on it.
Related
The M-register profiled across SPV, banking, crew licensing and finance.
Learn more →The rules that decide tax, licensing and import, regardless of the flag.
Learn more →Holding, SPV, VAT and financing, designed around your aircraft.
Learn more →This watch is general; your transaction is specific. If one of this quarter's changes touches an aircraft you are financing, importing or operating, we can read it against your structure — independently, and on your side. Flyxchain does not broker aircraft and takes no transaction commission. Contact us to discuss your case.
Request a ConsultationGeneral information, current as of 2026. Not legal, tax or financial advice; all requirements must be confirmed with the registry and qualified local advisors.