Prepared in support of the Luxembourg–Georgia Aviation Expedition 2026 | Courtesy of AOPA Turkey
Introduction
The Luxembourg–Georgia Aviation Expedition 2026 brings together a diverse group of European aircraft, ranging from certified General Aviation types — Cessna, Cirrus, and similar — to nationally regulated ultralight aircraft (ULMs). When such a group crosses international borders, it inevitably presents documentation that may look unfamiliar to receiving authorities. This is not because anything is missing or irregular. It reflects the genuine complexity of European aviation regulation, where two legitimate frameworks operate side by side.
This document has been prepared to assist the Turkish Civil Aviation Authority in reviewing expedition participants’ files with full confidence. We are grateful to AOPA Turkey for facilitating this process.
Two frameworks, operating in parallel
EASA-certified aircraft — the Cessnas, Cirrus, and touring aircraft that make up the majority of international traffic — follow a framework familiar to most aviation authorities worldwide. Their documentation is standardised across Europe.
ULMs are different. Under European legislation, they fall into the category of “Annex I aircraft” — intentionally excluded from EASA’s scope and regulated instead by each country’s national civil aviation authority. For example, a French-registered ULM is overseen by the DGAC (Direction Générale de l’Aviation Civile). Many Luxembourgers register their plane in France, because of the ease of regulation. Each National Civil Aviation Authority issues its own documents, in its own format, in its own national language.
This is by design, not by oversight.
The French ULM documention set — a practical example
A ULM registered under the French framework carries four documents, all issued by the French DGAC/DSAC. Understanding what each document is — and is not — removes any ambiguity.
1. Carte d’identification ULM (ULM Identification Card) The primary registration document, printed on yellow paper and bearing the aircraft’s identification marks, type, serial number, and owner details. This is the ULM equivalent of an aircraft registration certificate.
The card explicitly states that its validity is illimitée — unlimited. This is intentional and correct. The card does not expire. What maintains its operational validity is the accompanying airworthiness declaration, described below.
2. Accusé de réception de la déclaration d’aptitude au vol (Acknowledgement of Airworthiness Declaration) This is the airworthiness oversight mechanism. The owner periodically declares that the aircraft remains airworthy, and the DGAC issues this acknowledgement in return. This document must be renewed every two years.
It serves a function analogous to an Airworthiness Review Certificate (ARC) under the EASA framework. Without a current acknowledgement, the identification card itself becomes invalid. The system therefore does provide time-limited airworthiness oversight — it simply distributes it across two documents rather than one.
3. Fiche d’identification ULM (ULM Technical Identification Sheet) A detailed technical data sheet covering the aircraft’s specifications: manufacturer, engine, propeller options, weights, and performance figures, issued by the DGAC. This document carries no expiry date, as it describes the aircraft’s physical and technical characteristics, which do not change.
4. Licence de station d’aéronef (Aircraft Radio Station Licence) The radio equipment authorisation, covering the onboard VHF radio and ADS-B transponder, with a fixed expiry date. Issued by the DGAC in accordance with international telecommunications regulations.
Summary for reviewing authorities
The absence of an expiry date on the Carte d’identification ULM is not an anomaly. The card itself states unlimited validity — this is the correct and intended wording under French ULM regulations. Ongoing airworthiness is demonstrated by the Accusé de réception, which must be renewed every two years and whose current validity can be verified on the document itself.
The documents are in French because they are issued by a French authority. This does not affect their legal validity or the aircraft’s compliance with its state of registry.
The complete document set — identification card, airworthiness acknowledgement, technical sheet, and radio licence — constitutes full and proper documentation for a French-framework ULM operating internationally.
Pilot responsibility
Each pilot-in-command on this expedition remains solely responsible for the legal operation and airworthiness status of their aircraft, and for compliance with the requirements of all states entered or overflown.
For any questions regarding the documentation of a specific expedition participant, please contact AOPA Turkey.
Regulatory reference: Regulation (EU) 2018/1139, Annex I; French Civil Aviation Code, Article R.133-1-2.
