The applicable law governing the revocation of an IDERA in Pakistan is the Cape Town Convention and Aircraft Protocol (Implementation) Rules, 2004 (the “Implementation Rules”) (which essentially incorporates the Cape Town Convention into domestic law) read together with the relevant air navigation orders and the airworthiness notices issued by the Pakistan Civil Aviation Authority (“CAA”) from time to time.
Procedure for revocation of an IDERA in Pakistan
For the purposes of revoking any existing IDERA which is currently recorded on the Pakistan Aircraft Register in favour of any authorized party, the authorised party or its duly certified designee is required to make an application to the CAA on a duly completed and signed prescribed Form CAAF-196-AWRG (“Form 196”).
Pursuant to paragraph D9.5 of the Air Navigation Order ANO-023-AWRG-2.0 (Registration of Civil Aircraft in Pakistan) dated 02 December 2023 (the “ANO”), the following documents are required to be submitted to the CAA in connection with the application for revocation of an IDERAs in respect of the Aircraft:
(i) duly completed and signed Form 196 by the authorized party or its certified designee;
(ii) priority certificate of the aircraft from the international registry (available at https://www.internationalregistry.aero/ir-web/);
(iii) proof of payment of specified fee prescribed in airworthiness notice bearing reference no. AWNOT-003-AWRG (Airworthiness Service Charges) dated 20 February 2026, as amended from time to time; and
(iv) power of attorney, where applicable.
In addition to the foregoing documents, the CAA may also require supporting corporate authorisations of the authorised party authorizing the named signatory to execute the relevant documents on behalf of the authorized party, including a duly notarized and apostilled board resolution authorising the issuance of any powers of attorney (if applicable) and submission of the revocation application. In the event a power of attorney is required and the same is executed outside of Pakistan, the CAA requires such power of attorney to be notarized and apostilled. Documents that are required to be notarized and apostilled must be attested by the competent authority at the place of execution of such documents.
Where the revocation of IDERA application is proposed to be submitted through a legal counsel acting as the attorney of the authorised party before the CAA, the CAA requires a duly executed power of attorney in favour of such legal counsel, granted by the relevant authorised party along with the relevant corporate authorization in favour of the named signatory on behalf of the authorised party. Such power of attorney must expressly authorise the attorney to submit applications, execute and file documents, and liaise with the CAA on behalf of the authorised party in connection with the relevant IDERA filing. If so instructed, we would be happy to prepare a draft form of the power of attorney for review.
Upon receipt of the revocation application along with the supporting documentation, the CAA may seek further clarifications or additional documents from the authorised party. Once additional clarifications or documentations, if requested by the CAA, are provided thereto, the Director General of the CAA may provide its approval for revocation of the existing IDERAs by way an official acknowledgment in writing.
Estimated Costs for revocation of an IDERA in Pakistan
(i) CAA Fees
The applicable fee payable to the CAA in respect of the applications for revocation of IDERA is as prescribed under Airworthiness Notice (Airworthiness Service Charges) bearing reference number AWNOT-003-AWRG-9.0 dated 20 February 2026 (as amended from time to time). The fee payable at the time of application for revocation of an IDERA is PKR 11,625.
(ii) Stamp duty
Under the Constitution of Pakistan, 1973, stamp duty is a provincial subject and would be subject to the territory in which the replacement IDERA is being executed.
(iii) Ancillary Costs
In addition to the costs associated with the filing of the applications, the legal fees for the relevant counsel(s) engaged by the authorized party to appear before the CAA in respect of the applications for revocation would be applicable (which may vary from counsel to counsel).
Prescribed timeline for revocation of an IDERA in Pakistan
There is no prescribed timeline under law within which the CAA is required to acknowledge the application for revocation of an IDERA. In practice, it may take between three (3) to seven (7) weeks from the date of submission of the application provided the CAA does not raise any additional queries or clarifications in respect of such application and its supporting documents. Such time may vary depending on how diligently the application is pursued with the CAA. Please note that the aforementioned timelines are indicative and may vary depending on the actual circumstances.