Regulatory update • Aircraft registration • N-register trusts
FAA invalidates 803 SACI aircraft registrations, raising immediate grounding risk for trust-held N-registered fleets
The US regulator has ordered the surrender of registration certificates linked to Southern Aircraft Consultancy Inc (SACI), with owners advised to re-register through compliant pathways before aircraft can operate lawfully.
The US Federal Aviation Administration (FAA) has taken a rare enforcement step against a trust services provider, declaring 803 aircraft registrations connected to Southern Aircraft Consultancy Inc (SACI) to be invalid and instructing the surrender of certificates within a 21-day window.
The decision has triggered urgent planning for aircraft owners and operators, particularly those flying business jets, turboprops, helicopters and piston aircraft registered via trust arrangements on the US N-register.
What happened
In a public notice dated 13 January 2026, the FAA said aircraft registrations associated with SACI were invalid and instructed SACI to surrender the related Certificates of Aircraft Registration within 21 days.
Not a routine administrative hold
“Invalid” registration language can create immediate compliance constraints, particularly for cross-border operations.
Fast-moving owner decisions
Owners may need to plan rapid re-registration through a compliant trustee or alternative national registry.
International ripple effects
Operators flying outside the US may face permit or insurer scrutiny if registry status is uncertain.
Why the FAA acted
Trust arrangements are commonly used to place aircraft on the US N-register. However, FAA rules require that the trustee entity behind a trust-based registration meets specific citizenship and eligibility criteria.
The FAA has indicated that SACI did not meet those requirements when registration applications were submitted, which is why the agency treated the resulting registrations as invalid.
Context: non-citizen trusts and scrutiny of control
The trust model has long been accepted in business aviation, including “non-citizen trust” structures used by foreign owners. Over time, regulators and industry participants have debated how trustees demonstrate independence and compliant “control” in practice, particularly where administrative functions sit outside the United States.
Why the Emiliano Sala case is still referenced
SACI has been referenced in industry discussions since the 21 January 2019 Emiliano Sala crash, in which the aircraft involved was held in a trust structure linked to SACI. While the FAA’s recent notice focuses on trustee eligibility rather than accident causation, the case remains part of the wider conversation about oversight of trust registrations.
Impact on owners, operators, insurers and lenders
For owners, the immediate concern is operational continuity. Beyond flight disruption, there are secondary issues that can escalate quickly, including insurance validity questions and financing covenant pressure.
| Area | What changes when registration is invalid | Typical risk to manage |
|---|---|---|
| Operations | Aircraft may be grounded until lawfully re-registered, especially for international flying. | High (mission disruption) |
| Insurance | Policies may contain compliance clauses; operating unlawfully can create coverage disputes. | Very high (uninsured exposure) |
| Financing | Loan covenants often require continuous registration and insurability. | High (default triggers) |
| Permits and approvals | Operators may need to update permits, AOC documentation, and flight authorisations after re-registration. | Medium–high (administrative delay) |
Practical note: The legal position and operational options can differ depending on where the aircraft is based, where it is intending to fly, and what the insurer and financier require in writing.
What owners should do next
If you suspect your aircraft is registered via a trust arrangement connected to SACI (or you are unsure), treat this as time-sensitive and verify your registry status before planning any flight.
48–72 hour checklist
- Confirm exposure: Verify the registered owner/trustee on the Certificate of Registration and cross-check with your management company.
- Pause non-essential flying: Avoid assumptions; do not operate if registry status is uncertain.
- Speak to your insurer/broker: Request written guidance on compliance expectations during re-registration.
- Review financing covenants: Identify “continuous registration/insurability” clauses and notify lenders early if required.
- Plan re-registration: Choose a compliant pathway (US trustee route or alternative registry) and assemble ownership evidence and paperwork.
- Coordinate operational approvals: Update permits and operator documentation as needed for international missions.
Longer-term takeaway for trust-registered aircraft
This episode is likely to increase attention on how trustee citizenship, independence, and administration are evidenced. For owners using any trust-based N-registration structure, periodic compliance reviews can reduce the risk of sudden operational disruption.
FAQ
Does “invalid registration” automatically mean the aircraft cannot fly?
In many scenarios, yes: aircraft may be treated as grounded until re-registered. The practical position can depend on location, mission profile, and what local authorities, operators and insurers require as proof of lawful status.
Can I keep flying while paperwork is being corrected?
Owners should avoid relying on assumptions. Obtain written guidance from your insurer/broker and specialist counsel, and confirm what permits and authorisations are required for the intended jurisdiction.
Will my aircraft finance agreement be affected?
Potentially. Many aircraft loans require continuous registration and insurance coverage. If registration becomes invalid, certain covenants may be triggered. Proactive lender communication is often important.
Is this only relevant to SACI aircraft?
The immediate issue is SACI-linked registrations, but the wider signal is that trust eligibility and “control” can face heightened scrutiny. Owners using any non-citizen trust structure should ensure governance and documentation are robust.
What is the quickest practical first step?
Confirm the trustee name on your Certificate of Registration and verify current registry status with your aircraft manager/operator. If SACI is involved, begin re-registration planning immediately.