Why so many aircraft are registered in Ireland, Bermuda or Malta

A Ryanair 737 taxis onto the runway at a German airport, but the tail doesn’t say EI- but 9H-. A Russian Airbus in old photos carries VQ-B instead of RA-. And in Dublin, there are companies that own hundreds of aircraft without you ever seeing one of them with an Irish registration. If you collect registrations, sooner or later you stumble over the question of why the country of registry so often doesn’t match the airline. The answer lies in a web of leasing, group structures and offshore registers. This guide untangles it and shows you what you can read from it as a spotter.

The short answer

A registration shows you only one thing: in which state the aircraft is entered in the aircraft register. This state of registry is responsible for airworthiness and oversight. Who owns the aircraft and which airline flies it is not stated there. With leased aircraft, these are often three different countries: the owner is based in Ireland, for example, the airline in Spain, and the register is also Spanish. Sometimes, though, the register is deliberately elsewhere, such as Bermuda or Malta, because airline and financiers see better legal or organizational conditions there.

The basic rule comes from the Chicago Convention of 1944: every civil aircraft needs a registration, and in exactly one state at a time. The prefix of the registration derives from the international radio call sign blocks; the basics are explained in Understanding aircraft registrations.

Owner, operator, state of registry: three roles

To understand offshore registrations, it helps to separate the three roles cleanly.

• Owner: For a great many commercial aircraft, this is not the airline but a leasing company or a purpose-built special purpose vehicle. According to industry overviews, the share of operationally leased jets was about 40 percent of fleets in 2017; in the mid-1970s, it was still under 2 percent. How these contracts work is covered in the guide Aircraft leasing explained.
• Operator: The airline with its air operator certificate (AOC). It flies the aircraft and provides crews and maintenance – or, in a wet lease, has another company fly for it.
• State of registry: The country whose authority enters the aircraft and assigns the registration. It issues the airworthiness certificates that other states recognize.

Normally, operator and state of registry are identical: a German airline flies with a D registration, an Austrian one with OE-. The owner, on the other hand, can be based almost anywhere. An Airbus owned by an Irish leasing company and flying with a German airline therefore carries a perfectly normal D registration. It only gets interesting when the register also deviates from the airline’s seat.

Constellation	Owner	Operator	Register	What you see on the tail
Classic leasing case	Leasing company in Ireland	Airline in Germany	Germany	D-
Group subsidiary	Airline group	Subsidiary with AOC in Malta	Malta	9H-
Offshore register	Leasing company or bank	Airline in a third country	Bermuda	VP-B or VQ-B
Own fleet	The airline itself	Airline	Home country	national prefix

Ireland: where the aircraft are owned, not necessarily where they are registered

It is no coincidence that so many leasing companies are based in Ireland. The story begins in 1975 in Shannon: back then, Aer Lingus, the Guinness Peat Group and the Aer Lingus executive Tony Ryan founded Guinness Peat Aviation (GPA). In the 1980s, GPA rose to become the world’s largest aircraft lessor. The 1992 IPO failed in the middle of an aviation crisis, the company ran into trouble with about ten billion dollars in debt and was restructured in 1993. Fleet management went to GE Capital Aviation Services, and from the remains, AerCap later emerged via several stages.

GPA’s real legacy is its people. Many former managers founded or led their own leasing companies, and so a dense network of lessors, lawyers, tax advisers and technical service providers grew up around Shannon Airport and above all in Dublin’s financial district. Incidentally, Tony Ryan also founded Ryanair on the side.

Today, according to its association Aircraft Leasing Ireland, the industry manages more than 64 percent of the world’s leased aircraft and assets of over 300 billion dollars. The reasons usually cited include the accumulated expertise, an investment-friendly tax system with many double taxation treaties and the close link to international financial law. Add a detail that spotters rarely notice: the International Registry under the Cape Town Convention, in which security interests in aircraft and engines are registered worldwide, is located in Ireland. Ireland ratified the aircraft protocol in 2005.

For you at the fence, that means: Ireland is the country of the owners. The EI registrations you see, by contrast, come mainly from Irish airlines themselves – above all Ryanair DAC and Aer Lingus. At Dublin Airport, for example from the Mound on Old Airport Road, you have the densest collection of EI registrations anywhere in front of your lens.

Bermuda: the classic offshore register

Bermuda works quite differently. The aviation authority of the British overseas territory, the Bermuda Civil Aviation Authority, itself calls its register the world’s first offshore register. It enters both private aircraft and commercial aircraft that aren’t based in Bermuda at all, and also operates a register for stored aircraft and transition phases between two leases. The registrations begin with VP-B or VQ-B.

Why would an airline register its aircraft on an island in the Atlantic? General reference works name three main motives for airlines from emerging markets: financiers’ concerns about the aviation oversight in the home country, doubts whether domestic courts would enforce the banks’ security interests, and the airlines’ reluctance to register the aircraft in the financier’s country instead – often the USA or Great Britain. A register with a British legal tradition and experienced technical oversight reassures banks and lessors because in an emergency, they can get hold of their aircraft more easily.

So that the state of registry doesn’t have to carry out every inspection itself somewhere in the world, the Chicago Convention contains Article 83 bis. It allows oversight duties to be transferred by agreement to the operator’s state. Bermuda explicitly lists aircraft operated under Article 83 bis as part of its commercial register.

The Russia case in 2022

How big Bermuda’s role was became suddenly visible in 2022. Many airliners of Russian companies, including aircraft of Aeroflot, carried VP-B or VQ-B registrations. After the start of the war against Ukraine, the following happened:

• At the end of February 2022, the EU banned the sale and leasing of aircraft to Russian airlines; existing leases had to be terminated by the end of March.
• On March 14, 2022, Bermuda suspended the airworthiness certificates for the affected aircraft.
• On the same day, Russia allowed its airlines to re-register the aircraft in the Russian register (RA-) – without the foreign owners’ consent.
• At the end of March 2022, the Russian government declared that more than 400 leased aircraft had been re-registered and would remain in the country.

Before the sanctions, Russian airlines had, according to reports at the time, leased about 515 aircraft worth around ten billion dollars from foreign lessors. Because the Bermuda entries were not properly deleted, many aircraft were suddenly in two registers – impermissible under international standards. For spotters, this is still visible today: photos from before 2022 show the same serial numbers with VP-B or VQ-B registrations that now operate as RA-.

Malta: an EU register for group subsidiaries

Malta is the third name that shows up strikingly often in registration lists, though for a different reason. Here it is less about lessors than about airlines with a Maltese operating license whose aircraft fly all over Europe.

The best-known example is Ryanair Holdings. Besides Irish Ryanair DAC with EI registrations, the group includes two Maltese companies:

• Malta Air was founded in 2019, initially together with the Maltese government, and is now a wholly owned subsidiary of Ryanair Holdings. Its 737-800s and 737-8200s carry 9H registrations but mostly fly in the normal Ryanair look, and a large part of them operate far outside Malta.
• Lauda Europe flies with a Maltese AOC and an Airbus A320 fleet for the Ryanair group, with bases in Vienna, Palma and Zagreb, among others – also with 9H registrations.

Why Malta? As an EU member, a Maltese airline may freely fly routes between other EU countries within the single market, and the aircraft are subject to the common EASA rules. At the same time, Malta has actively courted aviation companies for years and ratified the Cape Town aircraft protocol in 2010, which matters to financiers. Which mix of tax, labor and organizational reasons tips the balance is rarely disclosed in detail by the companies. For you, the practice counts: a Ryanair aircraft with 9H- on the tail is a different collectible than one with EI-, even if both look the same.

You know Malta’s home airport, Malta International, mainly as a destination, by contrast – you will get most 9H Ryanair jets in front of your camera at completely different airports.

Other registers with an international audience

Bermuda and Malta are not alone. Other smaller jurisdictions also run registers that deliberately appeal to foreign owners – especially for business aircraft. A well-known example is the Isle of Man, with registrations that begin only with M-. If you come across a business jet with an unusual prefix on a general aviation apron, there is often such a register behind it. If you want to compare the systems of large national registers, you will find them in the guides to British G registrations and German registrations by weight class.

A special case is transitional registrations. When a lease ends, the aircraft is deleted from the old airline’s register before it is newly entered with the next operator. In between, it can carry a temporary registration for ferrying, storage or conversion – Bermuda even has its own register for that. For collectors, such short-lived registrations are real rarities.

What this means for you as a spotter

Offshore registrations make the hobby more complicated but also more exciting. You should know a few consequences:

If you want to follow a particular aircraft over the years, take a look at the guide Tracking an aircraft by registration. And if you collect registrations deliberately, Collecting registrations has ideas for how to sensibly mark such special cases in your own list – for example, separate entries for the same serial number under EI- and 9H-.

What to watch out for

• State of registry is not the owner’s country. Leasing companies from Ireland are behind a large part of the world fleet, but their aircraft mostly carry their airlines’ registrations.
• One group, several registers. For groups with subsidiaries in different countries, the prefix reveals which company is currently operating the aircraft.
• Document historic registrations cleanly. Old VP-B and VQ-B photos of Russian airliners are part of history – label them with the date so they don’t get mixed up with today’s RA registrations. Tips on this are in Labeling photos properly.
• Take dual registrations seriously. Aircraft that have been re-registered since 2022 without their owners’ consent are legally disputed. For your collection, they still count – with the registration under which you saw them.

Conclusion

That so many aircraft are flying with Irish, Bermudan or Maltese registrations has three different causes. Ireland is the center of the leasing industry and thus above all the country of the owners, but its EI registrations come predominantly from Irish airlines. Bermuda is a genuine offshore register that offers airlines and financiers legal certainty – especially visible with Russian airliners until 2022. Malta, in turn, is home to group subsidiaries like Malta Air and Lauda Europe, whose 9H jets fly across Europe. If you know this logic, you read far more from a registration than just a country.