Specialized Aircraft Registries: Key Structural Differences

While the Registry of Aruba was formed in 1995 as a public-private partnership between the Aruba DCA and a private company in the USA – the registry is headquartered in Miami – the Isle of Man Aircraft Registry is an operating unit within the Isle of Man Civil Aviation Authority and is thus part of the IOM state government.

Having operated as a cost-neutral IOM government entity since it was formed it 2007 – i.e., it seeks to make some return on revenues annually, but all proceeds are re-invested in the unit, according to Colin Gill, Deputy Director of Civil Aviation for the Isle of Man – the IOM registry’s business model is substantially different to that of the Aruba registry.

Rather than offering an annual-subscription package approach to service provision as Aruba does, the IOM registry charges individual fees for each of its services.

It does so for several reasons, according to Gill. First is that the IOM registry offers clients a wide variety of services, ranging from pilot-license validations to flight-operations certifications, and from mortgage services (via a secure Register of Aircraft Mortgages it maintains on all IOM- registered aircraft) to carbon-offsetting services under the UK Environment Agency administration, under ICAO’s CORSIA market-based mechanism.

The second reason the IOM registry charges fees individually is that this allows its clients enormous flexibility in selecting which services they require and can afford.

Providing each aircraft with its CoA and certification of registration are core services for the registry and many of its other services require those two certifications being in place, but most of its other services are optional and so each client can customize its particular service requirement.

Thirdly, the IOM registry “reflects the UK model – our charges are no more complex than those of other registries, and we have a much more transparent website,” which lists publicly its entire fee structure and service menu, Gill says.

To make its fee structure fully understandable to any customer thinking of using its services, the IOM registry is also happy upon request to provide customers with detailed cost estimates for the services they are considering selecting.

Each estimate assumes an average number of manhours (calculated on the basis of averaging the costs of many previous requests) is required to perform the services requested and it takes into account any travel and on-site surveying which any of the services involve, according to Gill.

The upshot of the IOM registry’s complete fee transparency is that none of its customers have ever complained that they don’t understand its fee structure or the final invoices they receive from the registry, he says.

Helping the IOM registry in this respect is that in almost all cases the documentation and operational matters involving the business aircraft it registers are either handled by professional aircraft-management companies, or the aircraft are operated by professional private or corporate flight departments well used to managing certifications.

Presumably the same circumstances apply to all other specialized aircraft registries – in Aruba’s case they do, according to according to Justin Berard, the registry’s Director of Business Development. The Aruba registry’s customers are also happy with its fee levels overall, he says.

For now, the IOM registry is maintaining its existing fee structure and policy, though as a responsible and responsive customer-service entity it does review its policy regularly. 

“We are weighing up package approvals,” Gill says, but the registry doesn’t appear close to making any substantial changes.

Centralized vs Decentralized Aircraft Registries

Another area of variation among BizAv-specialized registries is whether it is a centralized or decentralized registry. This criterion describes whether the registry records all mortgages and – in at least one case (the FAA registry) – performed-service liens on its registered aircraft.

Performed-service liens are those raised against aircraft by MRO facilities, air navigation service providers and airports for unpaid charges, for example.

If a registry doesn’t record mortgages, it is described as a de-centralized registry and anyone seeking financial documentation affecting an aircraft to sell, lease or de-register it from the registry has to look elsewhere for the relevant information.

Centralized registries also may (or may not) hold all of an aircraft’s maintenance logs and other documentation, as provided to them by the owner when required.

In cooperation with the national DCA, the Aruba registry holds maintenance-status information and historic records on its registered aircraft.

While the Isle of Man registry doesn’t hold aircraft maintenance logs, it employs its own aircraft technical surveyors and also holds contracts with various third-party surveyors to perform on-site airworthiness surveys on each aircraft in its registry.

It does so to ensure that each aircraft meets all relevant ICAO and national-DCA airworthiness standards, to issue each aircraft’s annual CoA.

Likewise, in cooperation with its national DCA, the Aruba registry uses airworthiness survey inspectors too, for the same purpose.

Some specialized registries – including Aruba’s, according to Berard – are largely centralized, though in many cases (Aruba among them) the registry needs to enlist the help of other agencies in its national/territorial government to provide the financial records involved. This is because the registry itself doesn’t record the liens, but another government department – in Aruba’s case the nation’s Mortgage Department – does.

However, even relatively de-centralized registries such as the IOM registry may offer recording and holding of lenders’ and leaseholders’ mortgages on aircraft as a service.

According to Gill, the IOM registry monitors its customers’ financial circumstances as closely as possible because “we use financial distress as an indicator of safety”.

In this respect, knowing whether an aircraft has performed-service liens outstanding against it is very useful information to have in performing the registry’s key role of ensuring its registered aircraft are maintaining the required airworthiness and air safety standards.

Owner vs Operator Aircraft Registries

Another common characteristic differentiating national/territorial aircraft registries from one another is whether the registry is an owner-based registry or an operator-based registry, or functions as both.

Owner registries register each aircraft by the owner named on the registration application form, while operator registries require the name of the entity or individual actually operating the aircraft in order to register it.

The Aruba and the IOM registries describe themselves as being both aircraft owner and operator registries because they require the names of the official owner of the aircraft and of the operator of the aircraft.

However, Gill stresses that the IOM registry “is an asset registry” rather than an owner registry, in that while it requires the official owner of each aircraft to be named in the registration application, it does not require the application to identify the beneficial owner of the aircraft.

In this manner, the IOM registry – and many others, including the FAA registry – allows the owner of the aircraft for tax and sale-proceeds purposes to remain concealed.

More information from:
Isle of Man: www.iomaircraftregistry.com
Registry of Aruba: www.theregistryofaruba.com