27 February 2026

On 1 May 2025, India’s Protection of Interests in Aircraft Objects Act 2025 (“Act”) came into effect, implementing the Convention on International Interests in Mobile Equipment (“Convention”) and the Protocol to the Convention on International Interests in Mobile Equipment on Matters Specific to Aircraft Equipment (“Protocol” and together with the Convention, the “CTC”).

On 17 September 2025, the Ministry of Civil Aviation of India published draft rules for the implementation of the Act (“Draft Rules”). Among other recommendations, the Draft Rules proposed: (i) the establishment of a parallel national register for the registration of international interests; (ii) the imposition of a requirement for creditors to notify the Directorate General of Civil Aviation (“DGCA”), India’s aviation authority, prior to exercising remedies; and (iii) the prioritisation of certain non-consensual liens which appears to go beyond India’s declarations under the Convention.

The Draft Rules raised concerns among global aircraft lessors, financiers, and the Aviation Working Group, that the creation of a parallel national register and expansion of non-CTC liens could raise compliance risks and complicate the repossession of aircraft from distressed carriers.

In response to concerns and suggestions proposed by various stakeholders, the Government of India, by way of a Gazette Notification dated 30 January 2026, notified the Protection of Interests in Aircraft Objects Rules, 2026 (“Final CTC Rules”). This Alert seeks to assess the Final CTC Rules and evaluate whether the concerns arising from the Draft Rules have been adequately addressed by the Final CTC Rules.

The Protection of Interests in Aircraft Objects Rules, 2026

·       Requirement to inform (not register) international interest with DGCA

·       Maintenance of records of dues

·       Notification prior to enforcement and exercise of remedies

·       Requirement to make payment of dues arising after default and non-consensual liens

·       Moratorium period upon insolvency

·       Non-judicial remedies

·       Conclusion: A step in the right direction

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