Please note that this article and the materials available herein are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain legal advice before operating to Cuba.

This business aviation blog post is part of a series on bizav ops to Cuba.

Over the past year we’ve seen quite a few changes in terms of easing of restrictions for N-registered general aviation (GA) operations to Cuba. While there’s been no real regularity to updates from the U.S. side, and Cuban authorities tend to not always announce regulatory changes in advance, operating restrictions continue to ease.

The following is an overview of what you need to know:

1. Purpose of flight

At this time tourism is not an accepted reason for U.S. citizens to visit Cuba. To make a trip to Cuba, your travel must fall under one of twelve general license categories (which we’ve covered previously) or meet requirements for a specific license. For travel under a general license we can often set up a GA trip to Cuba in as little as 24-48 hours, assuming all required documentation is in order. On the other hand, if you need to apply for a specific license, the process could take several weeks or months to complete.

2. Cuban landing permits and local sponsors

To obtain a Cuban landing permit you’ll need to provide a local sponsor name and contact details. The Cuban Civil Aviation Authority (CAA) will contact your sponsor to confirm they’ll vouch for your flight and purpose of travel. Note that the sponsor must be a professional sponsor, such as a local business, government entity or cultural/sports/educational establishment. A hotel, travel company, or transportation provider does not qualify as a sponsor for GA operations to Cuba.

3. Arrival and departure

Passengers are meant to use the same means of transport when arriving/departing Cuba. If you arrive on a private non-revenue aircraft, you should leave on a private aircraft, and the same goes for commercial transport options. Note that passengers may use different aircraft and operators for arrival and departure as long as it’s the same mode of travel – private non-revenue, charter (non-scheduled commercial), or scheduled commercial.

4. Length of stay

The U.S. Commerce Department Bureau of Industry and Security (BIS) currently limits the length of stay for U.S. registered aircraft to seven consecutive days in Cuba. If you want to stay on the ground more than seven days you’ll need to obtain a Temporary Sojourn license from BIS and this process can take several weeks. Alternatively, you may depart Cuba – to the U.S. mainland or Puerto Rico – and return to Cuba for an additional stay of up to seven consecutive days.

5. Departure and arrival airports

As of April 2016, there’s no longer a requirement to use portal airports when operating between the U.S. and Cuba. GA operators may travel from/to any airport in the U.S. or U.S. territories/possessions having customs, immigration, and quarantine (CIQ) clearance capability. However, keep in mind that if you’re returning from Cuba to the U.S. mainland, you’ll need to first land at a designated airport of entry (AOE) unless you have a Border Overflight Exemption (BOE). On the Cuban side, GA operators may only arrive and depart international legs at Havana (MUHA), Cayo Largo Del Sur (MUCL), Camaguey (MUCM), Holguin (MUHG) and Varadero (MUVR). This restriction is imposed by Cuban authorities and may change in future.

6. Domestic operations

In the past, U.S. authorities permitted N-registered operators to make only one stop in Cuba. However, this restriction has been removed. Once in Cuba, GA operators have no restrictions on the number of domestic legs permitted. While Cuban authorities only allow you to arrive and depart at the five AOEs above for international legs, there are no limitations on domestic travel within the country. To fly domestic legs operators need approval from Cuban CAA, in the form of a landing permit, and must have instrument flight rule (IFR) flight plans on file. We recommend that your Cuban landing permit list all domestic legs you intend to fly to in advance. If you decide to add flight legs once in Cuba, your 3rd-party provider can make the necessary changes to your permit, but it’s at the discretion of CAA if they will approve it or not. Currently there are no cabotage restrictions relating to internal travel within Cuba, but such restrictions may be imposed at a later time.

Conclusion

We anticipate further easing of regulations and requirements for N-registered operators and U.S. citizens traveling to Cuba. However, it will take time for further changes to take place. For the time being, it’s important to be aware of all applicable documentation and operating compliance issues, in order to enjoy and smooth and trouble-free operations to Cuba.

Stay tuned for Part 2, which covers customs, immigration, visa, and supporting services for travel to Cuba.

Questions?

If you have any questions about this article or would like assistance planning your next trip to Cuba, contact me at keithforeman@univ-wea.com.

Please note that this article and the materials available herein are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain legal advice before operating to Cuba.