Subject: RE: Inquiry Regarding Eligibility for 100% Ownership and Director Role in Estonian Air Operator
From: "Helen Reinhold" <[email-masked]>
To: "'Oleksandr Sharai'" <[email-masked]>
Date: Tue, 5 Aug 2025 13:05:46 +0300

Your: 19.05.2025 no 3.3-6/25/8198-1

Our: 05.08.2025 no 3.3-6/25/8198-2

Dear sir,

Thank you for your interest in obtaining an air operator's certificate from 
the Estonian Transport Administration (ETA). Estonia, as a member state of 
the European Union, follows the rules and procedures established in the 
European Union when issuing AOCs and OLs.

The common procedure involves a preliminary meeting with the potential 
applicant, during which the content and process of the future application 
are discussed. This is followed by the submission of a formal application 
with the necessary documents and the review and assessment of the 
application and submitted documents by the inspectors of the ETA. If 
everything is in order, an air operator certificate is issued. More 
information available 
https://www.transpordiamet.ee/ariline-lennutransport#lennutegevusloa-valj.

Several Estonian airlines operate outside Estonia. However, we would like to 
point out that we monitor compliance with the Principle Place of Business 
rules quite closely.

The principal place of business of the company must be located in Estonia. 
(Principal place of business – the head office or registered office of the 
airline where the main financial and operational management of the airline, 
including the management of continuing airworthiness, is carried out).

The conditions of the principal place of business are met, among other 
things, if:

-the company is registered in Estonia;

-the actual management of the activities and financial activities are 
controlled, decided and managed by responsible managers, including the CEO, 
with a place of business in Estonia;

-official business is carried out in Estonia, including meetings (announced 
and unannounced) are held at the company's principal place of business;

-all document management, including the preservation of documents related to 
the management of the company's activities and financial activities, and the 
documentation of these decision-making processes must be available at the 
organization's principal place of business in Estonia.

See as well attached EASA WP about PPoB.

As a member state of the European Union, Estonia follows the rules and 
procedures established by EASA. More detailed information as well as the 
applivcation forms can be found here 
https://www.transpordiamet.ee/taotlused-blanketid#lennutegevus-ja-koo

Kind regards

Helen Reinhold
Head of Flight Operations Department

Aviation Division
+372 56 30 1520
Lõõtsa 5/11415 Tallinn

 <http://www.transpordiamet.ee/> www.transpordiamet.ee

From: Oleksandr Sharai <[email-masked]>
Sent: Monday, May 19, 2025 10:39 AM
To: [email-masked]
Subject: Inquiry Regarding Eligibility for 100% Ownership and Director Role 
in Estonian Air Operator

Dear Sir or Madam,

I am writing to inquire about the eligibility requirements for establishing 
and operating a non-commercial complex aircraft operator (NCC) and 
subsequently applying for an Air Operator Certificate (AOC) in Estonia.

Specifically, I would like to clarify the following:

Can a person who holds a valid Estonian residence permit (but is not an EU 
citizen) be 100% owner and general director of an aviation company 
registered in Estonia?

Are there any additional limitations or requirements related to the 
nationality or residency of the company’s management or shareholders?

Would such an individual meet the conditions required for oversight and 
control as set forth in EASA regulations?

Your guidance on this matter would be greatly appreciated. I am planning to 
establish an aviation business with full regulatory compliance and would 
like to ensure all requirements are met from the start.

Thank you in advance for your time and support.