ABSTRACT
Aircraft finance issues are only fragmentarily governed by EU law. Notwithstanding the basic freedom of movement of capital, EU law incorporates other regulations that will be relevant to aircraft finance in the context of Brexit. First, EU law imposes some limitations on aircraft leasing. Second, English law is commonly chosen as the governing law of financing transactions, even if they have no geographic connection with the UK. Third, Brexit may have an impact on aircraft registration rules. Aircraft ownership is the domain of national laws and is neither governed by the Chicago Convention nor directly regulated by EU aviation law. Finally, Brexit may introduce changes as regards laws governing security agreements, which usually accompany aircraft financing transactions. The core of financial security law was traditionally a domain of the domestic regulations of the state in which the aircraft registry was located.
