Wet Leasing a Non EU Aircraft into Europe: Approval, Time Limits and Lead Times
Updated: Sep 29
European airlines short of capacity, whether from engine inspections, late deliveries or a stronger season than planned, often find that the quickest available aircraft sits outside the EU. A 737-800 or A320 with crew from a well run operator in the Middle East, Africa or Asia can be ready within weeks. The aircraft is rarely the problem. The approval is.
Under EU rules, an EU airline that wet leases an aircraft registered in a non EU country needs prior approval from its own licensing authority, and that approval is only given for specific reasons and for limited periods. This guide explains what the regulator looks at, how long an approval runs and how early a lessee should start the file. For the basic differences between wet, damp and dry leasing, see our ACMI vs dry lease vs wet lease guide.
Who needs the approval
The rule sits in Article 13 of Regulation (EC) 1008/2008, the EU's air services regulation. It applies to the lessee: the EU carrier that will sell the flights under its own name and licence. The lessor keeps operational control, because in a wet lease the aircraft flies on the lessor's air operator certificate with the lessor's crew, maintenance and insurance.
Two separate checks run in parallel:
The commercial approval from the lessee's licensing authority, under Article 13.
The safety side: the non EU operator must meet safety standards equivalent to EU rules, and in practice it will need an EASA Third Country Operator (TCO) authorisation to fly commercial services into the EU. If the lessor does not already hold one, that alone can decide whether the plan works.
An operator that already flies into Europe, holds a TCO authorisation and has wet leased to EU carriers before is a very different proposition from one that has never done it.
The three permitted reasons
The regulation allows wet leasing of a non EU registered aircraft only where the lessee can justify it on one of three grounds:
Exceptional needs. Approval can be granted for up to seven months, renewable once for up to seven more.
Seasonal capacity needs that cannot reasonably be met by leasing an aircraft registered in the EU.
Operational difficulties, where leasing an EU registered aircraft is not necessary or not possible. Approval then lasts only as long as strictly necessary.
Most summer and winter peak leases rely on the seasonal ground, and the words "cannot reasonably be satisfied" matter. Authorities may ask what EU registered capacity the airline looked at, so keep a short record of the EU lessors approached and their answers.
The operational difficulties ground covers cases such as a grounded fleet. It is flexible in timing but tightly limited in duration.
Reciprocity
An authority may also refuse approval if there is no reciprocity on wet leasing between the EU or the member state and the country where the aircraft is registered. This rarely stops a lease on its own, but it is worth checking early when the lessor is from a country with limited aviation agreements with Europe.
The US exception
Where an international agreement concluded by the EU provides otherwise, the time limits can be different. The EU and US air transport agreement is the main example, which is why wet leases involving US carriers are treated differently from those with most other countries.
What the file usually contains
Each authority has its own forms, but a lessee should expect to provide:
The signed or near final wet lease agreement.
The lessor's AOC and operations specifications, and its TCO authorisation where required.
Certificates of registration, airworthiness and noise for each aircraft.
Insurance certificates naming the lessee.
The reason for the lease, the period and the routes.
For seasonal cases, evidence that suitable EU registered capacity was not reasonably available.
Missing documents are the most common cause of delay, and the lessor's side is often the slowest, so ask for it in the first week. Our ACMI quote checklist lists what a lessor needs to price the lease.
How long it takes
There is no single answer, because timing depends on the authority, the season and the lessor's history. As a working rule:
An experienced lessor with a TCO authorisation and a complete document pack can often be approved in a few weeks.
A lessor new to Europe that still needs a TCO authorisation should be planned in months, not weeks.
Authorities are busiest just before the summer season, when many carriers file at once.
For a summer 2027 programme, that means shortlisting aircraft and lessors in the autumn and winter before, not in spring. Our 737-800 and A320 winter wet lease guide covers the market side of the same planning problem.
The United Kingdom is separate
Since leaving the EU, the United Kingdom runs its own regime. UK airlines wet leasing in foreign registered aircraft deal with the UK Civil Aviation Authority, which requires its own approvals and permits and sets its own policy on when foreign wet leases are acceptable. An EU approval does not carry over to UK operations, and the reverse is also true. A lease that serves both markets needs both processes.
Common mistakes
Choosing the aircraft before checking the operator's approvals. A cheaper aircraft from an operator without a TCO authorisation can cost the whole season.
Assuming the seven month limit covers every case. The seven month limit, with one renewal, applies to exceptional needs. Seasonal and operational cases are judged on their own facts.
Leaving insurance until last. Insurers need the routes, the lessee name and the period. Late certificates hold up approvals.
Signing firm without a condition for approval. The wet lease should state what happens to deposits and minimum hours if approval is refused or delayed.
Talk to us about a wet lease into Europe
Jetvice sources wet lease capacity from operators that already fly into Europe and understand the approval process, for narrowbodies, regional aircraft and freighters. See our aircraft leasing page for the lease types we arrange.
To get a quote, email info@jetvice.net with:
Aircraft type and number of seats or payload needed.
Start date, end date and expected block hours per month.
Routes and bases, and the country of your AOC.
The reason for the lease (seasonal peak, fleet grounding or another operational need).
Whether you need an operator that already holds an EASA TCO authorisation.
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